President Andrzej Duda signed the act on equalization taxation, the Chancellery of the President of the Republic of Poland announced. The new tax is expected to cover several thousand companies.
The act aims to implement the EU Global Assurance Directive minimum level of taxation of international business groups and large domestic groups. According to the announcement of the Deputy Minister of Finance, Jarosław Neneman, the new tax will cover approx. 7,000. companies.
According to the impact assessment of the regulations attached to the project, the new regulations are expected to increase budget revenues by over PLN 23.9 billion over 10 years (with total expenditure in this period amounting to almost PLN 370 million).
The Act enters into force on January 1, 2025, with the exception of certain regulations that enter into force on the day following the date of announcement.
Equalization tax. For whom
The new regulations will apply to constituent units of an international group or a domestic group if in at least two of the four tax years immediately preceding the tax year they achieved group revenue of at least EUR 750 million.
Such entities will have to estimate the amount of income obtained – according to the principles described in the Act – and then estimate amount of taxes paid. This will enable them to carry out effective tax rate test. If the effective rate turns out to be less than 15 percent, the company will have to pay equalization tax.
It may refer to earlier years
The Act also provides for an additional equalization tax, which applies to earlier years, and which may occur when the company makes adjustments that will lead to a reduction in taxes, especially CIT, taken into account when calculating the effective tax rate.
After such a correction, the company will have to recalculate the income from the year to which the correction applies and the effective tax rate. If it turns out to be lower than the one calculated earlier, you will have to pay additional tax.
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