Monday, 1 September 2025
On 20 May 2025, the Council of Ministers approved a third set of legislative proposals under its ongoing deregulation initiative, aimed at reducing administrative burdens and improving legal clarity for investors, entrepreneurs, and financial institutions. The new package, prepared in cooperation with the Ministry of Finance, introduces amendments to several laws covering taxation, inheritance, restructuring, and investment funds.
One of the key proposals focuses on updating the rules for tax refunds in the event of revocation of permits or decisions supporting investments in the Polish Investment Zone (PSI) or Special Economic Zones (SEZ). Under the current system, entrepreneurs are required to return the entire amount of public aid, even if only part of it was used. The new legislation will allow businesses to repay only the tax exemptions linked specifically to the income from activities associated with the revoked decision or permit. This change is expected to make the tax exemption system more attractive and fair, especially for companies planning to expand or invest further in Poland.
The amendments also aim to ease the functioning of general partnerships and tax capital groups. General partnerships will no longer be required to submit annual information about their shareholders if there has been no change in their composition. For tax capital groups, the revised law removes the automatic loss of corporate income taxpayer status if a transaction with an external related party is found to be non-market based, regardless of the scale or intent. This will enhance legal certainty and operational stability for businesses operating within such structures.
Significant changes are also proposed for the Act on Inheritance and Donation Tax. The updated rules simplify tax settlements for recurring benefits such as pensions and bring back the previously used method of reporting only summary information to tax authorities. The changes respond to complications introduced by a recent Supreme Administrative Court ruling and are expected to streamline tax administration for both citizens and authorities. Additionally, individuals will no longer be required to obtain tax office certificates confirming payment or exemption when acquiring property through a notarial deed or from close family members, further reducing bureaucratic requirements.
The third deregulation package also includes amendments to banking and restructuring laws. Currently, bankruptcy and restructuring proceedings are hampered by limited access to financial data due to banking secrecy regulations. The new provisions will authorize banks and cooperative credit unions to share protected financial information with court-appointed administrators, receivers, and supervisors involved in insolvency procedures, ensuring smoother proceedings and better protection of creditors’ interests.
Changes are also being made to facilitate mergers of non-public closed-end investment funds managed by the same fund management company. Presently, these mergers require a supermajority vote from fund participants, which often proves difficult to obtain. The new regulations will lower the threshold for consent from two-thirds to a simple majority. If the required participation is not met at the first meeting, a second assembly may be convened, and approval can be granted with the majority of those present or represented. This modification is intended to make fund consolidations more practical and responsive to market needs.
The proposed amendments to personal income tax, corporate income tax, inheritance and donation tax, the Banking Law, and the Act on Investment Funds and Management of Alternative Investment Funds are expected to take effect in stages. Most of the measures will come into force either on 1 January 2026 or within 14 days following their publication in the Journal of Laws.
This latest package continues the government’s effort to streamline regulatory frameworks and encourage investment by reducing legal and procedural complexity in key areas of economic activity.
