Introduction: What is the global minimum tax?

From 2025, Poland has implemented rules concerning the global minimum tax of 15%. This regulation, known as Pillar Two, is part of the international OECD initiative to combat aggressive tax planning.

The goal is to ensure that large capital groups pay at least 15% effective income tax in each country where they operate. If a company or group pays less, it must pay an equalization tax.

The question that entrepreneurs ask themselves: does this apply to me? The answer depends on the size of the group and business structure.

Pillar Two (Pillar II) — what it is and where it comes from

The global minimum tax is the result of OECD work under the BEPS 2.0 (Base Erosion and Profit Shifting) initiative. The initiative is based on two pillars:

• Pillar One: Changes to profit taxation rights (applies to the largest technology companies)
• Pillar Two: Global minimum tax of 15% (applies to capital groups with revenues exceeding 750 million EUR)

In Poland, Pillar Two applies. Pillar One is still subject to negotiations at the EU level.

Does it apply to Polish companies? Who is covered?

The global minimum tax applies to capital groups, not individual companies. Here are the key criteria:

It is estimated that Pillar Two affects approximately 8,000 companies in Poland. For most SMEs, this is not a concern.

How does the global minimum tax work? The mechanics of taxation

Think about Pillar Two in the following way: if a capital group pays less than 15% effectively in a given country, it must make up the difference.

Example 1: A company in Poland with an effective tax rate of 19%

Example 2: International group with low effective rate

In this example, the group would have to pay an equalization tax to reach a minimum of 15% effectively.

Implementation of Pillar Two in Poland: When does it start?

Poland implemented Pillar Two rules as follows:

Transition periods

• From January 1, 2025: Full obligations for tax years beginning from that date
• Voluntary application: Groups may apply the rules voluntarily for tax years beginning after December 31, 2023
• Declaration: Groups may file a declaration between March 1 and May 30, 2026 (for periods 2024–2025)

Where to report?

In Poland, Pillar Two obligations are coordinated by:

• Ministry of Finance — regulations and interpretations
• Tax Office — documentation and reports
• Tax advisor or accountant — calculations and form completion

Exemptions and exceptions: When does Pillar Two not apply?

Even if a group has revenues above 750 million EUR, there may be exemptions:

Geographic exemption

Business activities in European Union countries may be exempted for a specified number of years (transition years). Poland is an EU member, but the rules may change.

Sectoral exemption

Some sectors may have temporary exemptions (negotiated at EU level):

• Financial institutions (banks)
• Insurance cooperatives
• Pension funds

Low revenue exemption

Groups with revenues below 750 million EUR annually are completely exempted.

Comparison: Poland (19% CIT) vs. 15% requirement

Poland's CIT rate is 19%, which is higher than 15%. Does this mean Polish companies are safe?

Nominal rate vs. effective rate

The nominal rate is the theoretical rate (19% in Poland). But the effective rate — the real one — is lower because of:

• Tax reliefs (e.g., R&D, education)
• Prior year losses (reduce income)
• Deductible costs (depreciation, severance)
• Business structures (sales between companies)

What to do if your group exceeds the 750 million EUR threshold?

If a capital group is subject to Pillar Two, the following steps should be taken:

Step 1: Calculate the effective tax rate

Prepare a GloBE (Global Base Erosion and Profit Shifting) report containing:

• Group revenues in each country
• Booked profits and losses
• Actual tax paid
• Effective tax rate

Step 2: Determine if the 15% requirement is met

Compare the effective rate with 15%. If higher — no action needed. If lower — proceed to step 3.

Step 3: Calculate equalization tax (QDMTT)

QDMTT (Qualified Domestic Minimum Tax) is the equalization tax that should be paid by the entity operating in Poland.

Calculation:

Step 4: File report to tax office

The GloBE report must be filed at the tax office. Required forms:

• Pillar Two Report (GloBE Rule)
• Detailed tax documentation
• Confirmation of effective rate calculation

Practical questions and answers

Does my small company need to worry about Pillar Two?

If you belong to a group with revenues below 750 million EUR — no. Almost 99% of Polish companies are exempt.

What if I work with an international capital group?

If the group has a Polish company and revenues above 750 million EUR, the rules may apply. Consult with a tax advisor.

Does 19% CIT in Poland guarantee safety?

No — reliefs and effective rates matter. If you have large severance, prior losses, or complex structure, check the effective rate.

How does Pillar Two affect group development plans?

It may change decisions about where to locate new subsidiaries. Countries with low tax rates (below 15%) will be less attractive for large groups.