This article will answer the following questions:

• what are tax strategies and which taxpayers were required to publish them?
• what is the scope of the repeal of the regulations?
• from when does the obligation to prepare and publish information on the implemented tax strategy cease to apply, and what are the implications for current obligations?

The repeal of Article 27c of the CIT Act means the removal of the obligation to prepare and publish information on the implemented tax strategy, as well as the requirement to notify the head of the tax office of the website address where this document was made available.

According to the transitional provisions, if the deadline for fulfilling the obligation to prepare and publish the tax strategy falls after the day preceding the entry into force of the Act, the taxpayer is exempt from complying with it. The key factor here is the moment the deadline expires.  

Amendment of regulations – repeal of Article 27c of the CIT Act

The Act of 25 June 2025 amending the Corporate Income Tax Act (Journal of Laws 2025, item 1074, as amended) repeals Article 27c of the CIT Act, thereby abolishing the obligation for the largest taxpayers to prepare and publish information on their implemented tax strategy. This amendment, part of the “Support for Business and Deregulation” programme, aims to simplify the tax system and reduce excessive administrative burdens.

The Act was passed by the Sejm on 25 June 2025, adopted without amendments by the Senate, and submitted for the President’s signature. In the final stage of the legislative process, doubts arose as to whether the Act would be signed by Andrzej Duda or his successor, Karol Nawrocki. Ultimately, the Act was signed on 5 August 2025, the last day of Andrzej Duda’s term of office, published in the Journal of Laws on 6 August, and entered into force on 7 August 2025.

What are tax strategies and which taxpayers were required to publish them?

From 1 January 2021, selected CIT taxpayers were required to annually prepare and publish information on their implemented tax strategy. This obligation applied to entities whose revenue in a given tax year exceeded the equivalent of EUR 50 million, as well as to tax capital groups—regardless of the revenue generated.

The tax strategy information included, among other things: 

• a description of processes and procedures ensuring proper fulfilment of tax obligations,
• details of transactions with related entities exceeding 5% of the balance sheet total of assets,
• the number of submitted reports on tax schemes (MDR),
• information on restructuring activities,
• applications for tax rulings,
• forms of cooperation with the National Revenue Administration.

The strategy had to be prepared, published on the taxpayer’s own website, and the head of the tax office had to be notified of the website address by the end of the twelfth month following the end of the tax year. Failure to comply with these obligations could result in a financial penalty of up to PLN 250,000.

Since when has the change been in effect, and what does it cover?

The key factor here is the moment the deadline for fulfilling the obligation expires. In other words, what matters is the legal status in force on the day the deadline for publishing the strategy falls. For example:

• taxpayers whose tax year coincides with the calendar year are no longer required to prepare and publish a tax strategy for 2024 – the deadline for this obligation (31 December 2025) falls after the new regulations come into effect;
• similarly, taxpayers whose tax year runs, for instance, from September 2023 to August 2024, and whose publication deadline would be 1 September 2025 (as 31 August is a Sunday), are also exempt from this requirement.

As a result, all obligations related to tax strategies with deadlines falling after 6 August 2025 no longer apply to taxpayers.

Practical implications of the changes

The amendment is a favourable development for the largest taxpayers – it removes a requirement that, in the view of many entities, did not add significant value to the tax system while generating considerable costs. Nevertheless, the tax strategy may still serve as an internal tool supporting tax risk management, streamlining processes, and facilitating communication with the National Revenue Administration.

If you have any questions or concerns regarding how the changes may affect your company’s obligations, we encourage you to contact our experts.