Upcoming Tax Changes

1. Value Added Tax (VAT)

The key proposed changes include:

• Abolition of the following prescribed forms:
  • Books of Outgoing and Incoming Invoices (Form I-RA and Form U-RA)
  • Report on Domestic Supplies subject to Reverse-Charge Mechanism (Form PPO)
  • Special Record of Goods Sold to Customers within Passenger Transport (Form PDV-F)
• Extension of the deadlines for submitting VAT forms (PDV, ZP, PDV-S, and PZ 42 and 63) to the last day of the current month for the previous month
• The obligation to provide consent for receiving e-invoices is being removed

The changes are expected to enter into force on January 1, 2026.

2. Corporate Income Tax

The key proposed changes include:

• Extension of the tax exemption, previously applicable only to investment funds, to pension funds without legal personality
• Introduction of an additional deduction of the tax base for sports sponsorship expenses
• Introduction of the possibility of applying alternative transfer pricing methods in certain circumstances (as previously provided for by the regulation)
• It is proposed that Advance Pricing Agreements (APAs) may also be concluded for ongoing transactions if supported by sound business reasons, rather than only before entering the transaction
• It is proposed that the tax liability arises on the last day of the prescribed deadline for filing the tax return, rather than on the actual date of submission
• All corporate income taxpayers will be required to file their tax returns electronically, regardless of the company size
• The procedure for claiming foreign tax credit has been defined in more detail

The changes are expected to enter into force eight days after their publication in the Official Gazette.

3. Global Minimum Tax on Corporate Profits

The key proposed changes include:

• Addition of the provision clarifying that the global minimum tax does not reduce the corporate income tax base
• For the calculation of the domestic top-up tax, accounting profit or loss is determined according to the accounting standard applied in the compilation of the consolidated financial statements of the ultimate parent entity; if this is not reasonably feasible, it may be determined using the local accounting standard

The changes are expected to enter into force eight days after their publication in the Official Gazette.

4. General Tax Act

The key proposed changes include:

• Once a year, the Tax Authorities may share analytical data on local taxes with local or regional government units, for taxes whose collection the tax authorities handle
• The requirement to provide data recorded in electronic form now applies to all entities holding information that can directly or indirectly affect the calculation of the tax base
• Abolition of the form OPZ-STAT-1 (Statistical Report on Due but Uncollected Receivables)

The changes are expected to enter into force on January 1, 2026.