OECD's Pillar Two in Poland

What is the OECD Pillar Two framework? 

The OECD Pillar Two framework introduces a global minimum corporate tax rate of 15%, designed to combat tax base erosion and profit shifting. This major change impacts multinational enterprises (MNEs) operating across multiple jurisdictions, creating complex compliance challenges. 

Understanding how this framework applies to your business is essential to minimising risks and maximising financial opportunities. 

When do the new rules take effect in Poland? 

The rules entered into force on 1 January 2025, but taxpayers have the possibility to apply them voluntarily from 1 January 2024.

Who is impacted by Pillar Two in Poland? 

The new law concerns:

• MNE groups having their subsidiaries in other countries (this includes Poland), where the parent entity is located outside of Poland,
• MNE groups having their subisidiaries in other countries, where the parent company is located in Poland,
• domestic groups operating exclusively in Poland.

Contrary to OECD Model Rules, the top-up tax involves not only MNE groups but also groups where all constituent entities are located in the Member State (e.g. in Poland).

What actions should organisations take now?

If your business is affected, taking proactive steps now can mitigate risk and keep you ahead of the changes. 

• Assess your organisation’s exposure to Pillar Two taxes.
• Review and enhance your financial reporting systems to meet new compliance requirements.
• Collaborate with experienced tax advisors to develop strategies for minimising your tax burden.
• Stay informed about ongoing regulatory updates in your jurisdiction.

Why choose RSM for Pillar Two compliance? 

RSM combines global insights with local expertise to provide tailored support for navigating the complexities of the OECD’s Pillar Two framework.

• Proactive solutions to minimise financial risks.
• Expert guidance on new tax regulations.
• Customised strategies to align with your business objectives.
• Localised expertise combined with the global network of RSM professionals.

As part of the implementation of global top-up tax, we offer the following services of our tax advisors. To facilitate compliance with Polish regulations:

• we will verify whether or not the company will be subject to top-up tax – as part of our services, we will check if the examined company belongs to a group to which the new regulations apply or if it is an exempt entity. We will also examine the possibility of benefiting from safe harbours set out in the draft act (both permanent and transitional). Additionally, we will help you to identify and implement processes which simplify verification of the group's obligations within the scope of global minimum tax;
• we will help you to gather the data required under Pillar 2 – we will support you in identifying and completing the data which are necessary to fulfil the new tax requirements related to Pillar 2. Additionally, we will help you to identify the roles of individual constituent entities of the group, so that the obligations of a particular company are clearly defined;
• we will establish the tax basis taking into account any potential deductions – in analysing the impact of the Pillar 2 Directive on the company, we will make the necessary calculations to determine the tax basis for global minimum tax taking into account all deductions or simplifications indicated in the draft act;
• we will determine the amount of top-up tax – on the basis of data received or calculations made, we will help the company to determine the amount of global minimum tax due;
• we will help to assess any potential doubts or risks associated with global minimum tax – we will help the company to identify areas of increased risk and put forward our recommendations and proposed solutions adjusted to your company's situation;
• we will prepare or verify tax returns or top-up tax information returns – after model forms for top-up tax reporting are published in the future. 

Get Pillar Two ready with RSM in Poland

Navigating the Pillar Two framework can feel overwhelming. RSM is here to simplify things for you. With expert guidance and tailored strategies, RSM helps middle market organisations in Poland adapt to these changes, ensuring compliance and optimising your tax outcomes.