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Poland Incorporating Latest Administrative Guidelines in Pillar 2 Global Minimum Tax Law

10 April 2025

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Proposed Changes

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Poland

Poland's Ministry of Finance is finalizing draft legislation to amend the Act on Equalization Tax for Constituent Units of International and Domestic Groups, which provided for implementation of the Pillar 2 global minimum tax in line with Council Directive (EU) 2022/2523 of 14 December 2022. The draft legislation amends the Act to incorporate the OECD Pillar 2 administrative guidelines issued in June 2024 and January 2025, which includes guidance on deferred tax liabilities, the allocation of taxes, the treatment of intermediary entities, and recognizing deferred tax assets that arise from various tax reliefs such as R&D incentives. Clarifications are also...