Poland’s special economic zones Tax Holiday Meets the 15 Percent Floor

FTZ News: Large companies that booked a Polish corporate-tax holiday on a new plant now share the saving with a second tax.

According to PwC’s Poland corporate summary and a 2024 PwC note on the draft top-up law, Warsaw has levied a global-minimum top-up, including a domestic minimum, since Jan. 1, 2025. Groups with at least 750 million euros of revenue in two of the four prior years pay the gap if their effective Polish rate sits under 15 percent. Thedy & Partners said in September 2025 that for the biggest taxpayers the holiday can stop doing the job it was sold to do. ATL Law, writing from Warsaw, Kraków and Katowice and updating the page on Sept. 21, ties the same problem to a government draft that would stretch support decisions from 15 years to 20.

Until 2018 you had to put the factory inside one of 14 special economic zones. The act on supporting new investment let a qualifying plant claim the holiday almost anywhere. Kostrzyn-Słubice still signs decisions for the German border counties. The Katowice zone does the same in Silesia. They are the clerks of the system, not a private tax code. Old zone permits run to Dec. 31, 2026. After that date the Polish Investment and Trade Agency’s site points investors to a support decision. The holiday itself is a slice of eligible capex or two-year payroll, 12 to 15 years, at the rate on the 2022–2027 regional-aid map — 50 percent in poor counties, nothing in parts of Warsaw, 15 percent near Poznań and Wrocław for a large firm from 2025.

A mid-size Polish manufacturer still gets that sheet. A group already in the OECD net does the sheet and then another. The exemption pulls the Polish rate down. The top-up pulls it back toward 15 percent. Poland’s domestic minimum is written so Warsaw collects first. The decision is not torn up. The check the group keeps is smaller.

Payroll and machines on the site take some pressure off under the OECD substance carve-out. From 2026 a new safe harbour for incentives tied to people and kit can soften the math further. An income holiday with no such hook looks worse on that paper than a grant or a refundable credit. Warsaw tax firms have talked since late 2024 about rewriting PSI so the instrument still means something. What ATL Law has in front of it is a longer clock on the same exemption, an online application, and a tax-office opinion when aid exceeds 25 million zlotys. There is no gazette notice that Kostrzyn-Słubice or Katowice has swapped the CIT window for cash toward a substation.

Treasurers at groups over 750 million euros will keep two files. Everyone else can still read the PAIH page as written, at least until the Journal of Laws prints the 20-year text./.