Tax reform 2027: what the planned changes to PIT, CIT and the lump-sum regime mean for business

The planned tax reform from 2027 is intended to change the distribution of the tax burden between employees, entrepreneurs and the largest companies. The draft provides for a gentler transition between personal income tax (PIT) thresholds, but at the same time a higher corporate income tax (CIT) for the largest taxpayers, a radical reduction of the lump-sum tax revenue threshold and an increase in the solidarity levy. For businesses this means having to recalculate salaries, tax advances, budgets, liquidity and the profitability of current forms of doing business.

Legislative and legal status of this article: 23 August 2026. The solutions described are at the draft stage and may change during the legislative process. All rates, thresholds and limits cited below come from the draft amendments – they are not law in force, and the final scope of the reform may still change.

Planned changes at a glance

The table below sets the current rules against the parameters envisaged in the draft. All values in the "Planned change" column are at the draft stage – they will only take effect if the provisions are enacted in the proposed shape.

What is the 2027 tax reform intended to involve?

Under the draft, the 2027 tax reform is intended to simultaneously ease the tax burden on some PIT taxpayers while increasing the burden on the largest companies, some entrepreneurs settling under the lump-sum regime and people with the highest incomes. It is therefore not a one-directional cut or a one-directional increase – it is a redistribution of the burden between groups of taxpayers.

The structure of the draft formally links the entry into force of more favourable PIT scale parameters with regulations increasing CIT and lump-sum tax revenue. In practice this means that the planned relief for some employees and specialists is meant to be financed by higher tax paid by the largest enterprises, tax capital groups and some people running sole proprietorships (JDG).

The planned effective date for most of the solutions is 1 January 2027. Before then, the provisions must go through the full legislative path, and their wording may change – which is why all the conclusions in this article should be treated as an analysis of the draft, not a description of law in force.

The new PIT scale from 2027

The draft envisages three fundamental changes to the tax scale: raising the first threshold from PLN 120,000 to PLN 130,000, introducing a new intermediate rate of 24% for income between PLN 130,000 and 150,000, and moving the 32% rate to income exceeding PLN 150,000. The tax-free amount is to remain at PLN 30,000.

What would the proposed scale look like?

• income up to PLN 30,000 covered by the tax-free amount (unchanged);
• above PLN 30,000 up to PLN 130,000 – a 12% rate (taking into account the tax-reducing amount);
• above PLN 130,000 up to PLN 150,000 – a new 24% rate;
• above PLN 150,000 – a 32% rate.

Bracket creep

Since the threshold was last changed, nominal wages in Poland have risen substantially, partly under the influence of inflation. The result is bracket creep: more and more taxpayers exceed the PLN 120,000 threshold purely because of the nominal rise in wages, without any real improvement in their financial situation. The new scale may soften the sharp increase in taxation once the first threshold is exceeded, but raising the threshold by PLN 10,000 only partially offsets the rise in nominal wages and the fall in the value of money.

Who might benefit from the planned PIT changes?

If the provisions are enacted in the proposed shape, the new scale could primarily benefit people earning income between the current and the new thresholds – that is, between PLN 120,000 and 150,000 a year. In practice these are mostly employees, managers, specialists and entrepreneurs settling on the progressive scale.

Estimates from the Ministry of Finance quoted alongside the draft suggest the benefit could cover around 3.5 million taxpayers, with a maximum annual saving of around PLN 3,600. These are general estimates, not a guaranteed outcome – the actual benefit depends on the level and structure of income, available reliefs and the form of taxation.

The mechanism itself can be illustrated with a simple example. At an annual income of PLN 140,000, the current PLN 20,000 surplus above the first threshold is taxed at 32%. Under the draft, PLN 10,000 would remain within the 12% bracket, and only the next PLN 10,000 would be covered by the 24% rate. On the scale parameters alone, this means about PLN 2,800 less tax per year. This is not a calculation of net pay – a full calculation requires taking into account contributions, reliefs and the taxpayer's individual situation.

The reform's impact on employers and HR/payroll systems

Changing the thresholds is not just a matter for the taxpayer – it also changes the parameters used by payers to calculate advances. If the provisions enter into force in the proposed shape, employers will have to update their HR/payroll system algorithms so that they correctly apply the new thresholds and the new intermediate rate.

Areas requiring attention:

• updating the algorithms for calculating PIT advances on salaries;
• the risk of errors in the month in which an employee crosses a further threshold – with three brackets instead of two, the number of rate switches during the year increases;
• the impact on planning salaries and payroll budgets for 2027;
• a possible easing of some wage pressure – a higher threshold and an intermediate rate increase net pay without raising the employer's costs;
• reviewing payroll and ERP systems for readiness for the new parameters;
• communicating the changes to employees and management.

The change to the thresholds alone is not grounds for amending the wording of employment contracts or civil-law contracts – it concerns the way advances are calculated, not the structure of remuneration. Reviewing HR/payroll processes before 2027 is worth planning as part of HR and payroll services.

50% deductible costs after the change to the thresholds

The 50% deductible-cost limit is currently linked to the upper limit of the first tax-scale bracket. If the draft retains that link, raising the first threshold to PLN 130,000 could mean a corresponding increase in the annual limit for author's (copyright) costs – a potentially significant, if incidental, benefit for creators and specialists settling using the 50% cost deduction.

Changing the scale parameters does not, however, change the substantive conditions for applying the relief. Applying the 50% cost deduction still requires:

• a work within the meaning of copyright law to have been created;
• the author's fee to be properly defined;
• documentation of the results of creative work;
• appropriate provisions in the contract or internal regulations;
• a record of the works created.

A bonus, a job title or the general nature of the work alone are not automatic grounds for applying the 50% deduction – what remains key is the creative result of the work and its documentation.

22% CIT for the largest companies and capital groups

The most important planned change on the CIT side is raising the standard rate from 19% to 22% for certain of the largest taxpayers. Under the draft, the higher rate would cover:

• taxpayers with annual revenue exceeding the equivalent of EUR 50 million;
• tax capital groups (PGK);
• specified constituent entities of international and domestic groups covered by the global minimum top-up tax rules.

Two distinctions matter here. First, the EUR 50 million threshold relates to revenue and serves as a qualifying criterion – it does not mean that only the excess above that amount would be taxed at 22%. A taxpayer meeting the criteria would have its entire income taxed at the higher rate. Second, the tax rate is not the same as the taxpayer's effective burden – the real impact of the change depends on the structure of income, reliefs, deductions and intra-group settlements. The draft also envisages a separate approach for banks; its final scope should be verified in the final wording of the provisions.

Raising the rate by 3 percentage points directly affects net profit and, indirectly, return on capital, business valuations, financial ratios, budgets, loan covenants, investment decisions and dividend policy. For boards and chief financial officers (CFOs), this is a signal to recalculate financial models before the changes take effect – for example as part of CFO support (available in Polish).

Simplified CIT advances and the impact on liquidity

Taxpayers using the simplified form of advances calculate them on the basis of tax due for prior years – that is, at the 19% rate. The draft envisages increasing advances calculated in this way by 15.8% for taxpayers subject to the 22% rate.

This is an important distinction: 15.8% is not an additional CIT rate. It is a mechanism for adjusting the amount of advances to the increase in the rate from 19% to 22% – 22 divided by 19 gives approximately a 15.8% increase. Advances thus remain a reflection of the tax that, under the draft, will be due on the annual settlement.

The practical consequence is nonetheless real: higher advances could affect current cash flow as early as the start of 2027, before a company files its first annual return under the new rules. CFOs should factor this effect into liquidity forecasts and 2027 budgets.

Lump-sum tax on recorded revenue – the threshold is to fall to EUR 250,000

The draft envisages a radical reduction of the revenue threshold entitling a taxpayer to the lump-sum tax on recorded revenue – from EUR 2 million to EUR 250,000 a year. This is a return to the original assumption that the lump-sum regime should be a simplified form of taxation for smaller businesses, not a preference for enterprises with multi-million turnover.

If the change enters into force in the proposed shape, it will be crucial to check the previous year's revenue – as a rule this is what determines eligibility for the lump-sum regime in a given year. Entrepreneurs exceeding the new limit should compare the lump-sum regime beforehand against the progressive scale, the flat tax and operating through a company. What is decisive is not only the rates but above all the level of business costs and margin: the lump-sum regime taxes revenue, not income, so at high costs it may be unprofitable even at a low rate.

There is no rule that a limited liability company will always be more advantageous. The decision requires an individual calculation taking into account CIT, taxation of distributions to shareholders, social insurance contributions, the health contribution and the cost of accounting and legal services. We carry out this kind of scenario analysis as part of tax advisory.

A 17% rate on the excess of revenue above EUR 300,000

Besides the entry threshold, the draft envisages a separate mechanism relating to revenue earned during the year. Under the assumptions presented, a 17% rate would apply to the excess of revenue above EUR 300,000 in situations specified in the draft.

These two parameters are not contradictory. The EUR 250,000 threshold relates to the right to choose the lump-sum regime and is assessed as a rule on the basis of the previous year's revenue. Current-year revenue, however, may increase after the tax year has already begun – it is for such situations that the draft provides for a 17% rate on the excess. The mechanism is thus intended to cover taxpayers who lawfully started the year on the lump-sum regime but whose revenue grows dynamically during the year.

The solidarity levy is to rise from 4% to 5%

The solidarity levy applies to individuals with the highest incomes – the basic criterion remains linked to income exceeding PLN 1 million a year. The draft provides for raising its rate from 4% to 5% on the excess above that amount.

This does not mean that all of a taxpayer's income is automatically subject to the levy. Only specified categories of income are included in its base, and the effects of the change should be assessed together with the form of taxation of the business, capital income and other sources covered by the levy. For business owners and families with complex income structures, we carry out planning in this area, among others, as part of our services for private and family businesses.

The 2027 tax reform and transactions with related parties

A change in tax parameters usually prompts businesses to reorganise – and some of that will be commercially justified. It is worth remembering, however, that the planned changes increase the differences in taxation between forms of business activity, which raises the importance of documentation and the economic reality of settlements.

Before 2027, it is worth re-analysing:

• B2B (business-to-business) cooperation models with related parties;
• transactions between shareholders and companies;
• settlements within capital groups, including transfer pricing;
• the economic justification for planned reorganisations;
• the risk of artificially splitting activity to avoid tax thresholds.

Reorganisations should have genuine commercial justification – they cannot serve solely to artificially circumvent tax provisions, because such actions carry the risk of a dispute with the tax authorities. If a reorganisation involves asset or succession structures, it is worth bearing in mind the parallel planned changes to the taxation of family foundations – we wrote about them in the article on the planned changes to the taxation of Polish family foundations from 2027 and on the family foundation service page. We handle larger reorganisation and consolidation processes as part of our mergers and acquisitions (M&A) advisory.

Who might benefit, and who might pay more?

The reform is redistributive in nature – its effects will differ for different groups of taxpayers.

Potential beneficiaries:

• people earning income between the current and the new PIT thresholds;
• some specialists and managers;
• taxpayers using the 50% deductible-cost allowance, if the related threshold-linked limit rises.

Entities potentially facing higher taxes:

• the largest enterprises with revenue above the equivalent of EUR 50 million;
• tax capital groups;
• some entities within groups covered by the top-up tax;
• entrepreneurs losing their entitlement to the lump-sum regime once the threshold is lowered;
• entrepreneurs exceeding the planned revenue limits during the year;
• people subject to the solidarity levy.

What should companies and entrepreneurs do before 2027?

The time remaining before the planned effective date should be used for orderly analysis, not hasty decisions. A recommended checklist:

• determine which of the planned changes affect the company or its owners;
• prepare simulations of the PIT, CIT, lump-sum tax and solidarity levy burdens;
• verify projected revenue for 2026 and 2027;
• recalculate the profitability of the current legal and tax form of the business;
• update budgets, cash-flow forecasts and financial models;
• check the impact of higher CIT on net results and covenants;
• prepare HR/payroll systems for the new PIT thresholds;
• verify the rules for applying the 50% deductible-cost allowance;
• analyse transactions with related parties;
• monitor the legislative process, including through the Government Legislation Centre;
• plan communication of the changes to employees and management.

Does the 2027 tax reform create a stable system?

It is difficult to give an unambiguous assessment today. The draft attempts to balance support for some PIT taxpayers against the state's budgetary needs, but at the same time increases the complexity of the system: the new intermediate rate, additional thresholds and separate mechanisms for the largest taxpayers mean more parameters to track – for taxpayers, payers and advisers alike.

From a business perspective, predictability matters. Frequent changes to tax parameters make it harder to plan investments, salaries and structures over the long term – regardless of whether any single change is favourable. A final assessment of the reform will only be possible once the legislative process has concluded and the final wording of the provisions has been analysed.

How can Zwyrtek Group help prepare your company for the 2027 tax reform?

The planned changes require not only tax analysis, but also recalculating their impact on salaries, liquidity, profitability, financing and the structure of the business. Zwyrtek Group combines tax advisory with financial analysis, accounting, HR/payroll services and support for management boards.

• analysis of the reform's impact on the company and its owners;
• simulations of PIT, CIT, lump-sum tax and solidarity-levy burdens;
• review of the legal and tax form of the business;
• modelling the impact of the changes on financial results and cash flow;
• support for CFOs and boards in updating budgets;
• audit of B2B models and transactions with related parties;
• review of HR/payroll systems;
• verification of the rules for applying the 50% deductible-cost allowance;
• support in reorganising a business or capital group;
• ongoing monitoring of the legislative process.

Would you like to check how the planned 2027 tax reform will affect your company, salaries or the way you conduct your business? We will prepare a scenario analysis and a practical adaptation plan – book a free consultation.

This article presents the solutions as drafted, as at the legislative status of 23 August 2026. The legislative process has not been concluded, so the scope of the changes, the rates, the limits and their effective date may change. This material is for general information only and does not constitute legal, tax or financial advice for any specific taxpayer.