Tax changes from 2027 – new PIT scale, higher CIT and lump sum reduction 

The change may be most significant for employees, managers, board members and entrepreneurs taxed under general rules, whose annual income is close to the current threshold of PLN 120,000.

Currently, the 32% rate applies to the excess of the tax base over PLN 120,000. If the bill is passed as announced, income between PLN 130,000 and PLN 150,000 will be taxed at a 24% rate, while 32% will only apply to the excess over PLN 150,000.

From the employer perspective, the change may also have implications for planning net salaries, bonus systems, and benefits. With salaries falling between the current and new tax brackets, it may be worth reconsidering salary calculations for 2027.

In parallel with the reduction of burdens on some PIT taxpayers, the project included in the RCL list envisages an increase in burdens on the largest CIT taxpayers.

Currently, the standard CIT rate is 19%. A 9% rate may be applied by certain small taxpayers and start-ups, provided they meet statutory requirements.

According to the planned solutions, the basic CIT rate is to increase from 19% to 22% for:

• entities with annual revenues exceeding EUR 50 million,
• tax capital groups.

This represents a 3 percentage point increase in the nominal rate. For a highly profitable company, such a change could significantly increase the nominal corporate income tax burden and impact the effective tax rate. Therefore, in large corporate groups, the impact of the new rate should be analysed not only by tax departments but also at the level of budgets, cash flow forecasts, investment valuations, and financing models.

The EUR 50 million revenue threshold means that entities that are close to this limit or may exceed it in 2027 require special attention.

In practice, it is worth analysing, among others:

• revenue forecast for the coming years,
• the impact of reorganization and intra-group transactions,
• the operating model of a tax capital group,
• the impact of the higher rate on the group's effective tax rate,
• assumptions adopted in budgets and investment models for 2027 and subsequent years.

It will be crucial for companies to determine how exactly the EUR 50 million threshold will be calculated and what transitional provisions will be introduced.

One of the most significant changes for the small and medium-sized enterprise sector is the reinstatement of the EUR 250,000 limit for the possibility of choosing the lump sum tax on recorded revenues.

The scale of the changes is significant. In 2026, a continuing entrepreneur can benefit from the lump sum tax if their revenue from the previous year did not exceed €2 million. For 2026, this equates to PLN 8,517,200.

The planned limit of EUR 250,000 would therefore be as much as 87.5% lower than the current limit expressed in euros.

This is potentially one of the most important changes in the entire package from the point of view of entrepreneurs.

The lump sum tax is particularly attractive for certain businesses with relatively low costs, as the tax is calculated on revenue, not income. If the limit is indeed lowered to €250,000, some businesses that currently easily fit the €2 million limit may lose the opportunity to use this form of taxation.

Entrepreneurs who lose the right to lump sum tax can compare the available forms of taxation, primarily the tax scale and the flat tax.

Companies with revenues close to the planned limit should first of all check from which year it will apply and what transitional provisions the project provides.

Another element of the reform included in the planned solutions is to increase the solidarity levy rate by 1 percentage point, from 4% to 5%.

Currently, the tax is 4% of the base established above PLN 1 million. The official DSF-1 form indicates that the basis for calculation is the amount of income after certain statutory deductions, then reduced by PLN 1 million.

For high-income earners, the benefit of the new PIT scale may therefore be partially limited by the higher solidarity levy.

When planning the remuneration of business owners, managers or people who simultaneously generate income from several sources, it will be necessary to look at the entire tax system, and not just at personal income tax rates.

The complete tax scale, after all changes, would be as follows:

The Ministry of Finance also announced a modification to IP Box preferences, specifying a 5% personal income tax rate. However, the August 19 announcement does not describe the mechanism for the planned change.

Currently, personal income tax payers who meet statutory requirements can benefit from a 5% rate on qualified income from certain intellectual property rights if they conduct research and development activities and, as part of that research, create, develop, or improve qualified intellectual property. Qualified rights include, among others, copyright to a computer program.

Companies and entrepreneurs using IP Box should follow further legislative work, as the project may still change.

The draft has already been published on the RCL, but the new solutions have not yet been adopted. However, 2027 is included in the multi-year budgets and financial plans of many companies, so it's worth preparing several scenarios at this stage and updating them as the legislative process progresses.

Firstly, large companies should check whether their revenues can exceed EUR 50 million and what impact a 22% CIT rate would have on their tax rate and cash flow.

Second, entrepreneurs using the lump sum tax should compare their projected revenues with the planned limit of €250,000. If the limit is introduced at this level, some taxpayers may be forced to change their taxation method.

Thirdly, high-income earners should analyse the impact of the new PIT scale and the higher solidarity levy together.

Fourth, companies using the IP Box should monitor the scope of planned preference modifications and avoid making long-term forecasts assuming that current rules will remain unchanged.

According to the project, the reform is to cover five important areas: