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Poland publishes draft legislation implementing global minimum tax (Pillar Two), with option to apply retroactively from 1 January 2024

26 April 2024

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Tax Alerts, Information Reporting, Legis...

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Poland

Draft legislation implementing Global Minimum Tax (GMT) in Poland was released in the late evening of 25 April 2024 on the Polish government's official website.The draft provisions provide for Qualified Domestic Minimum Top-Up Tax (QDMTT) in addition to the Income Inclusion Rule (IIR) and the Undertaxed Profit Rule (UTPR).According to the draft law, the relevant Act would be in force from 1 January 2025, with optional application of QDMTT Safe Harbor and IIR as of 1 January 2024The proposed legislation provides for Transitional Safe Harbor rules as well as a permanent QDMTT Safe Harbor. Legislation proposed in Poland to implement the...