Key implementation point
Estonian CIT regime available in Poland: profits deferred until distribution create complex deferred tax timing differences under GloBE.
Implementation detail
- 01 Poland enacted the Supplementary Tax Act with effect from 1 January 2025 — one year later than most EU peers.
- 02 Poland-specific: Estonian CIT regime (deferral until distribution) has complex GloBE interaction — deferred tax adjustments required.
- 03 UTPR not enacted in the first wave; QDMTT and IIR included.
- 04 Krajowa Administracja Skarbowa (KAS) has published implementation guidance.
Enacted legislation
Ustawa o opodatkowaniu wyrównawczym
Official sources & further reading
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