Energy trading exempt from the minimum CIT

Energy suppliers may be able to avoid an additional tax burden. The Director of the National Tax Information Office (KIS) has confirmed that increases in costs relating to wholesale energy trading may be excluded from the minimum CIT.

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In an individual interpretation dated 6 February 2026 (0111 KDIB2-1.4010.509.2025.2.DD), the tax authorities confirmed that companies engaged in the wholesale trade of energy may benefit from the exemptions provided for in the regulations on minimum income tax.

Szymon Lipiński

Senior Tax Consultant at Crowe Poland,

in an article for Rzeczpospolita.

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The article is available in Polish only.

This interpretation may have implications that extend beyond the energy sector itself. It sets out a direction for interpreting the minimum CIT rules that takes account of business realities and the impact of market factors on companies’ results. This is a signal to companies in other sectors operating on low margins that it is also possible for them to effectively mitigate the risk of excessive taxation