CIT Increase for Banks in Parliament

On October 2, 2025, the government’s draft amendment to the Corporate Income Tax Act and the Tax on Certain Financial Institutions Act was submitted for its first reading in the Sejm (Parliament) (print no. 1752).

This marks the beginning of the parliamentary legislative process for the announced reform. Considering the planned effective date of January 1, 2026, the legislative work should be completed by the end of November 2025.

Draft Overview

The draft does not differ significantly from the earlier announcements and the version published on the Government Legislation Centre’s website. It provides for an increase in the corporate income tax (CIT) rate for domestic and foreign banks, as well as for Tax Capital Groups (Pol. PGK) that include banks — to 30% for the tax year beginning in 2026, 26% for the following year, and 23% thereafter. The draft also includes the previously announced reduction of the tax on certain financial institutions (the so-called “bank tax”), though this change would only take effect from January 1, 2027.

In addition, the proposal contains anti-avoidance provisions intended to prevent lowering the tax burden by exploiting mechanisms expressly provided for in the CIT Act — such as changing the taxpayer’s fiscal year or paying “simplified” CIT advances.

A new element is the recognition of banks qualifying as “small taxpayers” under the CIT Act. For these entities, the tax rate is to increase from 9% to 20% for the tax year beginning in 2026, 16% for the following year, and 13% thereafter.

Taxpayer Actions

Taxpayers affected by these changes may respond in various ways. A likely course of action is to conduct CIT compliance reviews to verify the tax base and identify potential optimization opportunities — or even consider business restructuring.

The Forvis Mazars team of tax advisors and experts is ready to carry out such tax reviews and assess business restructuring plans to ensure compliance and CIT risk mitigation while supporting legitimate business objectives.