The most important tax and legal changes from 2025
The new year brings not only new challenges but also a series of significant changes in legal and tax regulations that may impact the operations of entrepreneurs. To help you better understand and adapt to these new regulations, we have prepared an overview of the key changes that came into effect in 2025.
1. Cash Basis PIT (Personal Income Tax)
Cash Basis PIT is a completely new solution that allows taxpayers to pay income tax only upon actual receipt of payment from their clients. This means that taxpayers will no longer need to pay tax at the time of providing a service, delivering goods, or issuing an invoice, as was previously required.
The same principle applies to recognizing purchase invoices as tax-deductible expenses. Invoices will only be considered as deductible when payment for the purchased goods or services is made.
Cash Basis PIT will be optional; however, to choose this solution, an entrepreneur must meet certain conditions:
- Independently operate a sole proprietorship, regardless of the chosen form of taxation.
- Ensure that the income from business activities in the year preceding the tax year did not exceed 1 million PLN,
- Maintain simplified accounting (Revenue and Expense Ledger – KPiR).
- Submit a written declaration to the relevant head of the tax office regarding the choice of the cash method by February 20 of the tax year.
Important! Entrepreneurs conducting business in the form of a civil partnership or a general partnership are not eligible to use the Cash Basis PIT.
2. Health Insurance Contribution (ZUS)
In 2025, the first phase of changes to the health insurance contribution payment for entrepreneurs will come into effect, namely:
- Exclusion of revenues and expenses related to the sale of fixed assets from the contribution base.
The revenue and costs associated with the sale of fixed assets (specifically the portion not included in tax-deductible expenses, i.e., unamortized amounts) will not be included in the calculation base for health insurance contributions. This solution is optional—entrepreneurs can decide whether to include revenue from the sale of a fixed asset and related costs in the contribution calculation base. If they find it beneficial, they may include them; if not, they are not obligated to account for these revenues in the contribution base. - Reduction of the minimum base for calculating the health insurance contribution.
Entrepreneurs taxed under general rules or with a flat tax rate currently pay a health insurance contribution of 9% or 4.9% of income, with a minimum amount of 9% of the minimum wage.
Starting in 2025, the minimum health insurance contribution for entrepreneurs taxed under general rules or with a flat tax rate will be reduced and calculated as 9% of 75% of the minimum wage.
The minimum health insurance contribution will amount to PLN 314.96 per month starting in 2025.
3. Allowance for Deducting Losses from Lump-Sum Taxed Revenues.
As of January 1, 2025, it will be possible to deduct losses from revenues taxed under the lump sum taxation scheme, specifically for private rental income and income from the sale of processed plant and animal products.
4. JPK CIT
Starting January 1, 2025, the largest corporate income taxpayers with revenues exceeding 50 million EUR will be required to maintain their accounting records exclusively in electronic form. These records must be submitted to the tax office without prior request after the end of the tax year (via JPK-CIT) by the deadline for filing the CIT-8 tax return, which is no later than March 31, 2026, for the 2025 tax year.
The new obligations require taxpayers to supplement their accounting records with data mandated by tax authorities in accordance with the logical structures of JPK_KR_PD (income tax) and JPK_ST (fixed assets), as part of the JPK CIT framework.
To properly collect and submit data to tax offices, updates, and in some cases, a comprehensive overhaul of accounting systems will be necessary.
This obligation will be introduced in stages:
- From January 1, 2026, it will apply to other CIT taxpayers who currently submit JPK_VAT records (active VAT taxpayers).
- From January 1, 2027, it will expand to include all remaining CIT taxpayers.
5. Global Minimum Tax (so-called Equalization Tax)
From 1 January 2025, this applies to international and domestic groups that have reported revenues of at least EUR 750 million in the consolidated financial statements of the ultimate parent entity in at least two of the four fiscal years immediately preceding the audited fiscal year.
This change stems from the Act of November 6, 2024, on Equalization Taxation for Subsidiary Units of International and Domestic Groups (Journal of Laws, item 1685). The new regulations introduce the so-called Global Minimum Tax (GloBE), aimed at preventing the largest entities from reducing their effective tax rate below 15%.
If a company pays a lower tax rate, it will be required to make up the difference to meet the 15% threshold, justifying the term “Equalization Tax.”
6. Accounting Records Threshold and Changes to Audit Limits
Starting January 1, 2025, the revenue threshold requiring entrepreneurs to maintain accounting records will increase. Sole proprietors, partners in civil partnerships, general partnerships of individuals, and professional partnerships will be required to keep accounting records if their revenues reach or exceed 2.5 million euros (up from the current limit of 2 million euros effective until the end of 2024).
The new thresholds will apply to financial years beginning after December 31, 2024.
Comparison of Current and New Regulations:
Aspect | Until December 31, 2024 | From January 1, 2025 |
Limit for Accounting Records | EUR 2 mln | EUR 2,5 mln |
Revenue Threshold for Audit | EUR 10 mln | EUR 12 mln (estimated) |
Balance Sheet Total | EUR 5 mln | Higher thresholds (to be determined) |
Employee Threshold | 50 employees | No changes with correction |
7. Excise duty on tobacco products
Starting from March 1, 2025, new excise tax rates will apply to tobacco products, innovative products, and e-cigarette liquid:
- The excise tax rate for cigarettes will increase by 25% to 345 PLN per 1,000 units.
- The excise tax rate for smoking tobacco will increase by 38% to 260.14 PLN per kilogram.
- The excise tax rate for cigars and cigarillos will increase by 25% to 655 PLN per kilogram.
- The excise tax rate for innovative products (heated tobacco products) will increase by 50% to 565.52 PLN per kilogram.
- The excise tax rate for e-cigarette liquid will increase by 75% to 0.96 PLN per milliliter.
8. Clarification of the method for determining the place of provision for certain services delivered virtually.
Starting from January 1, 2025, the regulations will specify that the place of provision:
- For taxpayers, the place of provision for admission services to cultural, artistic, sports, scientific, educational, entertainment, or similar events, such as fairs and exhibitions, as well as auxiliary services related to admission to these events, when attendance is virtual, will be determined based on the general rules for establishing the place of provision for taxpayers. This will most often mean that the place of provision will be where the service recipient’s business establishment is located.
- For non-taxable persons, the place of provision for services in the fields of culture, arts, sports, science, education, entertainment, and similar services, such as fairs and exhibitions, as well as auxiliary services related to these activities, if they pertain to events that are broadcast or otherwise made available virtually, will be the location of the recipient’s registered office, permanent residence, or habitual residence.
9. Allowing foreign taxpayers to benefit from the subjective exemption.
As of January 1, 2025, the subjective VAT exemption will apply to:
- Taxpayers with their place of business located within the territory of Poland, based on Article 113 of the VAT Act, and
- Taxpayers with their place of business located in an EU Member State other than Poland, based on Article 113a of the VAT Act.
However, this exemption will not apply to taxpayers with their place of business in non-EU countries, as they are not covered by either Article 113 or Article 113a of the VAT Act.
10. Establishing the Polish conditions under which Polish taxpayers can benefit from exemptions similar to the subjective exemption, as specified by the regulations of other Member States.
As of January 1, 2025, conditions will be established under which Polish taxpayers can benefit from exemptions provided by the regulations of other Member States that are similar in nature to the subjective exemption.
11. Expanding the scope of the possibility to individually determine depreciation rates for self-constructed non-residential buildings, premises, and structures.
Legal Status as of December 31, 2024 | Legal Status as of January 1, 2025 |
Currently, the possibility for taxpayers to individually determine depreciation rates for self-constructed fixed assets that are non-residential buildings (or premises) and structures may exist if the fixed asset is located in a municipality that meets the following conditions:
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As of January 1, 2025, the possibility for taxpayers to individually determine depreciation rates for self-constructed fixed assets that are non-residential buildings (or premises) and structures will exist if the fixed asset is located in an area that meets the following conditions:
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Legal Basis:
Article 14c of the Act of July 26, 1991, on Personal Income Tax.
Article 81 of the Act of August 27, 2004, on Healthcare Services Financed from Public Funds.
Article 1a of the Act of January 12, 1991, on Local Taxes and Fees.
Article 9(1c) of the Act of February 15, 1992, on Corporate Income Tax.
Articles 96, 96b, 113a, 113b of the Act of March 11, 2004, on Value-Added Tax.
Article 2 of the Act of September 29, 1994, on Accounting.
Articles 99, 99a, 99b, 99c of the Act of December 6, 2008, on Excise Duty.
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