Poland’s Ministry of Finance announced on November 5, 2025 that it is seeking public feedback on the draft GloBE Information Return (GIR)—the new compliance form for the global minimum tax. The GIR will allow tax authorities to verify whether large multinational groups are meeting the 15% minimum tax rate introduced in Poland on January 1, 2025, as part of the OECD’s international tax reform. Developed by the OECD, the GIR is a standardized reporting tool designed to make sure global compliance. The consultation also includes an electronic version of the form and a set of troubleshooting codes to assist taxpayers. Comments are open until November 17, 2025.
The Draft Consultation can be accessed here.
Poland’s Council of Ministers has approved a proposal that would allow corporate groups to keep their tax capital group status even if they fail to meet arm’s length standards in transactions with related parties outside the group. Currently, such violations can lead to the costly breakup of the group, forcing each company to file taxes separately. The change, part of broader deregulation efforts, aims to prevent disproportionate consequences for transfer pricing missteps, especially given their complexity. Transfer pricing rules will still apply, but the penalty of losing group tax status would be removed. If passed by parliament, the measure takes effect January 1, 2026.
To read more on the proposal, click here.
On November 15, 2024 the President of Poland signed a new law that establishes a 15% global minimum tax for large corporate groups, that will enter into force starting from January 1, 2025. The law establishes rules to calculate effective tax rates and determine which corporate units will be subject to supplementary tax. Finance ministry estimates suggest around 7,000 entities in Poland fall under the law, though most will be unaffected as they already meet the tax requirements. The 15% minimum tax is part of a broader OECD agreement on global tax reform.
On September 4, 2024, the Polish Ministry of Finance updated its FAQs on domestic transfer pricing reporting obligations. Among the provided information, key topics include transfer pricing reporting (TPR) requirements, controlled transactions subject to TPR requirements, and the calculation methods of the transfer pricing amount. The updates further address the process for submitting corrections via TPR-C (5) forms, reporting after company dissolution, or following a takeover by a foreign entity.
In addition, the guidance explains TPR form types for general partnerships, criteria for micro or small entity status, and reporting transaction data using safe harbor simplifications.
Finally, the guidance notifies taxpayers with a tax year matching the calendar year to submit transfer pricing information for 2023 by November 30, 2024.