Thursday, 23 April 2026
From time to time, public debate in Poland returns to the issue of how much tax large companies actually pay relative to the scale of their operations. The discussion is often driven by cases in which companies report substantial revenues, maintain a strong market presence, and serve large customer bases, yet record relatively low taxable profits and, consequently, limited corporate income tax (CIT) payments.
This perception is particularly visible in the retail sector. Data published by Ministry of Finance Poland has highlighted significant differences in effective tax contributions among companies with broadly comparable market positions. Some firms report sizeable tax payments, while others, often during expansion phases or operating on thinner margins, report limited taxable income. While such outcomes are consistent with the design of CIT, which applies to profit rather than turnover, they continue to fuel questions around competitive balance.
A similar pattern can be observed in the courier sector. According to figures cited by Infor, InPost reported revenues of approximately PLN 9.85 billion and paid around PLN 375 million in corporate income tax in 2024, reflecting its relatively strong profitability. By comparison, DPD, FedEx and DHL eCommerce reported lower tax payments alongside lower reported profits, despite generating significant revenues in the Polish market. Such differences are typically linked to variations in business models, cost structures, and investment cycles, rather than revenue levels alone.
In the case of global technology companies, the structure is different again. Firms such as Alphabet, Meta Platforms, Netflix and TikTok generally operate in Poland through subsidiaries that provide marketing, research, or support services. Revenue from advertising or subscriptions is often recognised in other jurisdictions, reflecting group-wide operating models. As a result, while economic activity takes place locally, a significant portion of taxable profit may be recorded elsewhere.
Several structural factors explain these outcomes. Corporate income tax is levied on profit, meaning that companies with high operating costs, significant depreciation, or accumulated losses may report limited taxable income. In addition, multinational groups have the ability to allocate functions, risks, and assets across jurisdictions. Transfer pricing plays a central role in this process, with intra-group payments for intellectual property, financing, or services influencing where profits are ultimately recorded. Polish tax authorities have increased their focus on this area in recent years, reflecting broader international trends.
At the same time, these dynamics are not limited to foreign-owned companies. Domestic firms may also benefit from elements of the tax system, particularly where scale and organisational complexity allow for more sophisticated financial structuring. The issue, therefore, is less about ownership and more about how modern tax frameworks interact with globalised business models.
Poland continues to rely on foreign investment, competition, and innovation as key drivers of economic growth. At the same time, ensuring a level playing field remains an ongoing policy consideration. Recent international initiatives, including the OECD-led minimum global tax framework, aim to address some of these challenges by setting a baseline level of taxation for large multinational groups.
Within this evolving context, the debate is likely to continue, balancing the need to maintain an attractive investment environment with the objective of ensuring that taxation reflects, as closely as possible, where economic activity takes place.
Source: WEI
