Poland GloBE Top-Up Tax Filing: What the Ministry’s Q&A Settles

On 25 May 2026 Poland’s Ministry of Finance published a question-and-answer page on the Act of 6 November 2024 on top-up taxation of constituent entities of international and domestic groups (Dz.U. 2024 poz. 1685, amended by Dz.U. 2026 poz. 347), the statute behind the Poland GloBE top-up tax. The ministry says the answers were prepared together with taxpayers, partly through tax consultations on key issues. They deal with three things: the election to apply the Act to 2024, the completion of the GLB-D1 domestic top-up tax return, and the GloBE Information Return (GIR).

The timing is tight. For a calendar-year group that elected into 2024, the Act put the 2024 GIR and the GLB-Z1 and GLB-Z2 notifications at 30 June 2026 and puts the 2024 returns and payment at 30 September 2026. Groups that did not elect file nothing for 2024 and begin with the 2025 year, and Article 156(3), together with one answer in the Q&A, decides whether a calendar-year group’s 2025 GIR falls due at the end of March 2027 or the end of June 2027.

Three distinctions carry most of the weight. A safe harbour removes a calculation and leaves the return in place. A central GIR filing abroad removes the Polish GIR only where the Article 133(4) conditions are met in a jurisdiction on the Article 133(6) list for which the exemption is available. The current list contains the other 26 EU Member States, but the Ministry expressly states that the exemption cannot be used for Estonia, Lithuania, Latvia, Malta or Slovakia. And 2025 is the first tax year for some groups and a second year for others.

Related reading: EU Tax Simplification Package 2026: What the DAC Recast Means for DAC6, DAC7 and CESOP Reporting

Poland GloBE top-up tax: the filing set and where it goes

The Act implements Council Directive (EU) 2022/2523, the EU Pillar Two directive. Since 18 March 2026 its first footnote also cites Council Directive (EU) 2025/872, known as DAC9. As the general rule, the Act applies to constituent entities of an international or domestic group where the group reaches the minimum group-revenue threshold of EUR 750 million in at least two of the four tax years immediately preceding the tax year (Article 4(1) and (2)), subject to Article 4’s rules for groups existing for fewer than four tax years and for tax years other than 12 months. Article 1 names three taxes, and each has its own return:

• GLB-I1: the return for the global top-up tax (globalny podatek wyrównawczy), the Polish counterpart of the income inclusion rule (IIR).
• GLB-D1: the return for the domestic top-up tax (krajowy podatek wyrównawczy), Poland’s domestic minimum top-up tax.
• GLB-U1: the return for the top-up tax on undertaxed profits (podatek wyrównawczy od niedostatecznie opodatkowanych zysków), the Polish undertaxed profits rule (UTPR).

Three notifications sit beside the returns. GLB-Z1 reports the start of the group’s initial period of activity. GLB-Z2 gives the details of the constituent entity that files the GIR in another jurisdiction and names that jurisdiction. GLB-Z3 notifies the choice of one constituent entity to perform the Article 134(1) return tasks for the others.

The ministry’s forms page lists all six GLB returns and notifications. GLB-I1 is provided through its XML/XSD/XSL files only on that page, while GLB-D1, GLB-U1, GLB-Z1, GLB-Z2 and GLB-Z3 also have online form links.

The GIR travels by a different road. According to the ministry, the information on top-up taxation (schema GIR-1) is filed through the service interfaces of the Jednolity Plik Kontrolny (JPK), with the production environment at e-dokumenty.mf.gov.pl. The ministry publishes the GIR-1 XSD and a separate document of GIR-1 validations and error codes. The schemas for GLB-D1 and the three notifications name the head of the Kujawsko-Pomorski Tax Office in Bydgoszcz (office code 0471) as the receiving authority. A team that has built e-Deklaracje submission for GLB-D1 therefore still has a second channel to test before its GIR is due.

Polish GloBE deadlines: the statutory calendar

Each filing period in the Act runs from the end of the tax year, and the first tax year gets three extra months. Article 130(1) defines that first year, for a given jurisdiction, as the first tax year for which a qualified IIR tax or a qualified domestic top-up tax is calculated in respect of entities located there, or a qualified UTPR or Divisions II, III or IV of the Act are applied to them. The operative periods are these:

• GIR (GIR-1): by the end of the 15th month after the end of the tax year (Article 133(1)); by the end of the 18th month for the first tax year (Article 133(10)).
• GLB-Z2: the same periods as the GIR (Article 133(7) and (10)).
• GLB-Z1: by the end of the 15th month (Article 129(4)); by the end of the 18th month for the first tax year (Article 129(5)).
• GLB-I1, GLB-D1 and GLB-U1, together with payment of the tax shown: by the end of the 18th month (Article 134(1)); by the end of the 21st month for the first tax year (Article 134(2)).
• GLB-Z3: no later than the return deadline for the first tax year covered by the choice. A missed notification makes the choice ineffective (Article 135(3)).
• Transitional floor: a GIR, GLB-Z1 or GLB-Z2 deadline that would fall before 30 June 2026 moves to 30 June 2026, and a return or payment deadline that would fall before 30 September 2026 moves to 30 September 2026. Where those deadlines fall in 2026, the GIR, GLB-Z1 and GLB-Z2 cannot be filed before 1 April 2026, and the returns and payment cannot be made before 1 July 2026 (Article 156(1) and (2)).

For a calendar-year group, the rules produce three patterns. A group that elected into 2024 had 30 June 2026 for the 2024 GIR and the GLB-Z1 and GLB-Z2 notifications, and has 30 September 2026 for the 2024 returns and payment and for any GLB-Z3 notifying an Article 135 choice that starts with 2024. A group for which 2025 is the first tax year files the 2025 GIR and the GLB-Z1 and GLB-Z2 notifications by 30 June 2027 and the returns and payment by 30 September 2027, unless Article 156(3) removes the first-year extensions. A group for which 2025 is not the first tax year, or to which Article 156(3) applies, works to 31 March 2027 and 30 June 2027. The 2027 dates are my arithmetic on the statutory month counts.

The 18-month period for the GIR, GLB-Z1 and GLB-Z2 and the 21-month period for the returns and payment belong to the first tax year only. From the second year onwards the Act runs on 15 and 18 months, and the Article 156 floors stop mattering once the ordinary deadlines move past 2026.

The Article 154 election for 2024: what the answers fixed

Article 154(1) opened a window from 1 March 2026 to 30 May 2026 in which a group could file a statement, in the form of a notarial deed, electing to apply the Act to its tax year beginning after 31 December 2023 and no later than 31 December 2024. The election is irrevocable. Once made, the Act applies to the group from 1 January 2024, and the election counts as imposing the global and domestic top-up tax on the group’s constituent entities for that year (Article 154(2)). The UTPR provisions do not apply to that year (Article 155(5)).

The statute split the paperwork by where the ultimate parent entity (UPE) sits. A Polish UPE filed for itself and the other Polish constituent entities, attaching their written authorisations with notarially certified signatures (Article 154(3)). With a foreign UPE, every Polish constituent entity filed, attaching the UPE’s consent in notarial-deed form together with a sworn translation into Polish (Article 154(4)). The Q&A added four readings:

• Changed group composition (question 1): the consent and every formal step had to come from the entities that belonged to the group in the 2024 tax year, including entities that had left the group by the filing date. The ministry’s reason is that the election makes those entities taxpayers by their own decision.
• Consent from abroad (question 2): where the UPE’s jurisdiction has no equivalent of the Polish notarial deed, the consent should take the form closest to it, one that guarantees authenticity and the highest evidential value.
• Who the UPE is (question 3): UPE status depends on the obligation, including a hypothetical one, to consolidate. Whether that entity actually prepares the consolidated statements is irrelevant, and separate rules may have another person prepare them.
• Group structure (question 4): the Act does not require a current group chart with the statement. Attaching one is allowed, is not an error, and may help in dealings with the tax office.

Question 6 dealt with a route the ministry was asked about directly: whether entities could perform reporting acts for 2024, such as filing a GIR, without making the election. The answer is no. The Act generally entered into force on 1 January 2025, and only the election brings 2024 inside it. The GIR section of the Q&A confirms the same point from the other side: a constituent entity whose group did not elect files no notifications, returns or information for the 2024 tax year.

With the window closed on 30 May 2026, the population of Polish entities reporting for 2024 is fixed.

A safe harbour still leaves a GLB-D1 to file

The first answer in the returns section is short. Where a safe harbour means no domestic top-up tax is calculated, filing GLB-D1 remains mandatory. The second answer says how to complete it. The Q&A gives the de minimis test of the transitional CBCR safe harbour in Article 148(1)(2) as an example of a case where no domestic top-up tax is calculated for the jurisdiction. The numeric fields that would otherwise feed the calculation are then completed with 0, and the ministry names field 90 (net profit or loss), field 91 (accounting income) and field 92 (qualified income or loss) among them.

Fields 20 to 22 in part C.1 are mandatory whatever the outcome, and each needs a Yes or a No. The GLB-D1 schema ties the three fields to the three tests of the transitional CBCR safe harbour in Article 148(1): field 20 to the excess-profit test in point 1, field 21 to the de minimis test in point 2, and field 22 to the simplified effective tax rate test in point 3. The Q&A describes the rule as universal for every GLB form where a mandatory field offers a Yes or No choice, so each such field needs an explicit No where the harbour was not used.

The CBCR safe harbour runs on a clock. The simplified minimum tax rate is 15% for tax years beginning in 2024, 16% for those beginning in 2025 and 17% for those beginning in 2026 (Article 147, point 6). The election can be made for tax years beginning no later than 31 December 2026 and ending no later than 30 June 2028, and if it was not made for a year in which the group was subject to the Act, it cannot be made in later years (Article 148(21)).

The Q&A also separated the safe harbour from the 2024 election. Using the CBCR safe harbour from 2025 does not depend on having filed the Article 154 statement (question 5 of the election section). A group that elected the transitional CBCR safe harbour for 2024 in another jurisdiction, covering its Polish constituent entities, did not have to file the Polish statement on that account; the 2024 settlement follows that jurisdiction’s rules and the Polish Act does not apply. Those Polish entities can, as a rule, use the transitional CBCR safe harbour in 2025 and later years.

GLB-D1 field by field: the readings the Q&A pins down

Most of the returns section is form mechanics, and several answers resolve fields that look ambiguous on the face of GLB-D1.

Field 10 and the missing Article 153a

Part A, field 10 asks whether the settlement is made in connection with Article 153a of the Act. That article comes from a draft amendment, the Minister of Finance and Economy’s bill amending the Act and certain other acts (project UC90 on the Government Legislation Centre site, created on 13 February 2026), and it is not part of the Act in force. The instruction is to tick No. The Sejm ELI record for the Act, checked on 29 September 2026, still lists the Act of 13 February 2026 (Dz.U. 2026 poz. 347) as its only amending act.

A natural person on a group tax return

Part B.1 lets the filer mark the taxpayer as a natural person. The Q&A explains why. In certain cases a civil-law partnership (spółka cywilna) can be a taxpayer of the top-up taxes, and because it has no legal personality under the Civil Code, its partners act for it. Choosing the natural-person option opens fields for the partner’s NIP, surname, first name and date of birth.

Fields 90 to 92 and Article 37

The three income fields follow Article 37. Field 90, net profit or loss, is the constituent entity’s net profit or loss referred to in Article 37(1), which is the base for determining its net accounting income or loss. Field 91, accounting income, is that net accounting income or loss, also covered by Article 37(1). Field 92, qualified income or loss, is the concept defined in Article 37(2).

Field 97 against field 132

These two look alike and serve different formulas. Field 97, jurisdictional qualified income, is the denominator of the formula in Article 11(4), net jurisdictional qualified income; Article 11(4) is the effective tax rate formula that Article 151(1) cross-refers to. Field 132, the sum of qualified income of all taxpayers, is the denominator of the formula in Article 27(1).

Joint ventures and payment

Joint venture entities and joint venture subsidiaries also file GLB-D1. In part S (settlement within a subgroup) they indicate that the settlement concerns a joint venture subgroup and give the subgroup’s name in fields 134 to 136, writing “Brak” (none) where no separate name exists. The tax itself can be paid to the taxpayer’s micro-account (mikrorachunek podatkowy). The Q&A points to the Minister of Finance and Economy’s regulation listing the taxes paid through micro-accounts, which includes the form symbols GLB-I1, GLB-D1 and GLB-U1.

Local GIR filing in Poland: the EU-only exchange limit

Article 133(1) puts the GIR obligation on every constituent entity located in Poland. One Polish constituent entity can file for the group’s Polish entities if all the others authorise it in writing (Article 133(3)). Article 133(4) lifts the obligation where equivalent information has been filed with the tax authority of a jurisdiction with which Poland has a qualifying agreement on the exchange of top-up tax information in force for the tax year, either by the UPE located there or by another group entity located there and designated by the UPE. The Act then still requires the Polish entity to notify its tax office, by the end of the 15th month, of the filing entity’s details and its jurisdiction (Article 133(7)). That notification is GLB-Z2.

The Minister keeps the list of qualifying jurisdictions under Article 133(6). The version on gov.pl dated 15 May 2026 names 26 jurisdictions, which are the other 26 EU Member States. Five carry an asterisk: Estonia, Lithuania, Latvia, Malta and Slovakia. The note says that in those jurisdictions it is not possible to file information corresponding to the GIR concerning Poland, and the ministry’s page on GIR exchange concludes that the Article 133(4) exemption does not apply to them.

The trap sits in an OECD document, Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year), first published on 18 May 2026 and revised on 25 June and 6 July 2026. Under it, the 2024 implementing jurisdictions agreed to use mechanisms available under their domestic law either to waive penalties on local GIR filing or not to enforce local filing before the exchange deadline, where the GIR was centrally filed in an annex jurisdiction by the filing deadline and the GIR notification was filed locally. The annex lists 33 jurisdictions, among them the United Kingdom, Switzerland, Japan and Canada. Footnote 3 narrows Poland’s participation: Poland joins the common understanding only with respect to the EU Member States in the annex. The revised footnote also records that the Slovak Republic joins for the annex jurisdictions with which it has an activated exchange relationship, and that Vietnam has not been able to join.

The Q&A gives the reason. Poland has no legal basis to exchange GIR information with jurisdictions outside the EU, so a GIR centrally filed outside the EU will not reach Poland through exchange, and the ministry says it then has to be filed in Poland. A central filing in the United Kingdom or Switzerland, useful for other annex jurisdictions, leaves the Polish GIR obligation where it was.

Cyprus is the reverse case. It appears in the Minister’s Monitor Polski notice of 5 June 2026 under Article 2(7) (M.P. 2026 poz. 605), which lists it among the jurisdictions that have implemented a qualified IIR, for tax years beginning from 31 December 2023, although it did not appear on the OECD Central Record when the Q&A was written. The Q&A relies on the European Commission’s Pillar Two FAQ, which says all EU Member States should treat Cyprus as having a qualified IIR in effect, because that status derives directly from Article 3(18) of Directive 2022/2523.

The content of the GIR changed in 2026. Article 133(9), as amended, splits it into a general section, covering filing information, the corporate structure and a general summary of how the rules apply, and a jurisdictional section with information on safe harbours and exclusions and the data needed for the effective tax rate, the top-up taxes and the UTPR attribution for each jurisdiction where the group operates. The detailed data scope sits in the Regulation of the Minister of Finance and Economy of 24 April 2026 (Dz.U. 2026 poz. 571), issued under the new Article 133(11) and in force since 27 April 2026.

DAC9 in Polish law since 18 March 2026

The Act of 13 February 2026 amending the Act on the exchange of tax information with other states and certain other acts (Dz.U. 2026 poz. 347) was published on 17 March 2026 and entered into force the next day (Article 13). Its footnote lists the directives it implements, among them DAC8, Council Directive (EU) 2023/2226, whose crypto-asset rules are covered in our CARF crypto tax reporting guide, and DAC9, Council Directive (EU) 2025/872 of 14 April 2025. DAC9 amends Directive 2011/16/EU on administrative cooperation, the directive that already carries the account data in our CRS reporting guide and the cross-border arrangement reports in our DAC6 mandatory disclosure guide.

For GloBE filers the amending act did two things. Its Article 4 amended the top-up tax Act. Article 133(8), under which the Minister made the GIR template available in the Public Information Bulletin, was repealed; Article 133(9) was rewritten into the general and jurisdictional sections described above; Article 133(11) now empowers the data-scope regulation; and Article 154(5) now sends the 2024 election statement to “the competent head of the tax office”. Its Article 1 added Division IVA, Articles 81a to 81h, on the automatic exchange of top-up tax information, to the Act of 9 March 2017 on the exchange of tax information with other states.

Under Article 81b, the Head of the National Revenue Administration (KAS) sends the general section to the implementing participating states where the UPE or a constituent entity is located, and each jurisdictional section to the participating state it concerns where that state has taxing rights under a qualified IIR or UTPR or applies a qualified domestic top-up tax. The exchange happens within three months after the GIR filing deadline, or within three months of receipt for a GIR filed late. Article 7 of the amending act phases this in: the exchange obligation covers GIRs for tax years beginning no earlier than 31 December 2023, KAS performs it for the first time after 30 November 2026, and for a first-year GIR the exchange deadline ends no earlier than 31 December 2026.

Articles 81c and 81e run between authorities. KAS informs the other state’s authority when information received through exchange in an Article 133(4) case appears to need correction of obvious errors, or when information that should have been filed there has not reached KAS through exchange within three months after the filing deadline. For the first tax year, Article 7(4) stretches that period to six months, ending no earlier than 31 December 2026. The Q&A does not say what KAS would then expect from the Polish entity.

The 2025 year: when the first tax year is already behind the group

The last answer in the Q&A has the largest effect on the calendar. Article 130 speaks of the first tax year in respect of a jurisdiction, and the ministry reads it as the first tax year for which the GloBE rules are applied to entities located in that jurisdiction. Its example: a Polish entity belongs to a group that did not elect into 2024, but a group entity located in another jurisdiction brought the Polish entity within its IIR for 2024. From the group’s perspective, the first tax year in Poland is then 2024.

The extended periods in Articles 129(5), 133(10) and 134(2) all attach to the first tax year. If that year was 2024 and the group did not elect, the group had no Polish filings for 2024 and, on the ministry’s reading, reaches 2025 without the extra three months. Article 156(3) reaches further. It disapplies those three extensions for any group that, for its tax year beginning between 31 December 2023 and 31 December 2024, was covered by rules in another Member State equivalent to Directive 2022/2523 (or, outside the EU, rules corresponding to the OECD Model Rules), had constituent entities in Poland in that year and did not make the Article 154 election. Its test is the group’s coverage by those rules in 2024, so on my arithmetic such a calendar-year group, whether or not a foreign IIR reached its Polish entities, is on 31 March 2027 for its 2025 GIR and GLB-Z2 (and GLB-Z1 where relevant), and on 30 June 2027 for its 2025 returns and payment.

The initial period of activity has its own transitional start. Under Article 128(1), it lasts no longer than the first five tax years of the group’s activity, and a year belongs to it only if, for that year, the group has constituent entities in no more than six jurisdictions, counting the UPE’s, and no more than EUR 50 million of net book value of tangible assets outside the jurisdiction holding the most tangible assets in the first year the Act applies to the group. For the years of that period in which those conditions are met without interruption, the Polish constituent entities of an international group do not calculate the domestic top-up tax or the UTPR (Article 129(1)).

Article 128(4) counts the five years of the initial period from the first day of the tax year in which the international group meets the Article 4 conditions. For a group within the scope of Directive 2022/2523 or the OECD Model Rules for its tax year beginning after 31 December 2023, Article 160 counts the five years of the initial period and of the domestic top-up tax relief from the first tax year beginning after that date, and the five years of the UTPR relief from the first tax year beginning after 31 December 2024. The domestic top-up tax relief falls away, though, for entities in respect of which any parent entity applies a qualified IIR (Article 129(2)).

The Q&A adds one reporting instruction for these groups. A group whose initial period of activity under Article 128 began in 2024 states that year in the relevant notification for its tax year beginning after 31 December 2024.

Frequently Asked Questions

Our group’s 2024 tax year ran from 1 July 2024 to 30 June 2025 and we elected. Do the 30 June and 30 September 2026 dates apply?

Only as floors. The election covered that year because it began after 31 December 2023 and no later than 31 December 2024. The Article 156(1) dates only replace deadlines that would otherwise fall earlier. On the ordinary first-year periods in Articles 133(10) and 134(2), my count puts the GIR at the end of December 2026 (18th month) and the returns and payment at the end of March 2027 (21st month), both later than the transitional dates.

Can one Polish entity handle the returns for all the Polish taxpayers in the group?

Yes, where at least two Polish constituent entities of the same group are taxpayers of the same tax. Under Article 135 they can choose one of them to file a single return covering the tax of each and the total, and to pay it. The choice lasts for a period of no more than five years and can be repeated; it is notified on GLB-Z3. The other taxpayers that made the choice are jointly and severally liable with the designated taxpayer for the tax of the years covered. The GIR has its own route: one entity files under the written authorisation of all the others (Article 133(3)).

How are corrections handled once a GIR or return has been filed?

Article 136 applies the correction rules of Chapter 10 of Section III of the Tax Ordinance to both the GIR and the returns, except in cases that give rise to additional top-up tax. The Q&A does not address that exception.

In which currency are the amounts calculated, and what goes into the Polish return?

Unless the Act provides otherwise, the taxes are calculated in the presentation currency of the consolidated financial statements (Article 2(3)). Tax calculated in a currency other than the zloty is converted at the National Bank of Poland average rate from the last business day before the last day of the tax year (Article 134(3)).

Does the Act reach a purely domestic Polish group?

Yes. The Act covers domestic groups, meaning groups whose constituent entities are all located in Poland (Article 2(1)(8)), on the same EUR 750 million test in Article 4. A domestic group does not calculate the domestic top-up tax for its first five tax years, counted from the first day of the tax year in which it meets the Article 4 conditions (Article 129(3)). For a group within the scope of Directive 2022/2523 for its tax year beginning after 31 December 2023, Article 160 counts those five years from the first tax year beginning after that date.

How long do the supporting accounting records have to be kept?

The Act added Article 74(4) to the Accounting Act: for entities subject to top-up taxation, retention periods are at least five years from the end of the calendar year in which the payment deadline under the top-up tax Act expired.

Is there a route to an entity-specific answer beyond the Q&A?

Since 1 January 2025 a constituent entity can apply to the Director of the National Tax Information (KIS) for a GloBE opinion. The ministry’s page sets an initial fee of PLN 15,000 and a main fee of PLN 15,000 to PLN 50,000 fixed by the Director, gives the Director eight months from the filing of the request, and makes the opinion valid for five years from issue.

Related Articles

• EU Tax Simplification Package 2026: What the DAC Recast Means for DAC6, DAC7 and CESOP Reporting: the Commission’s 2026 proposals and why current filings continue until adoption and transposition.
• CARF: The New Global Tax Reporting Framework for Crypto: scope, reportable data and DAC8 timing for crypto-asset service providers.
• CRS Reporting in Luxembourg: Practical Guide for Financial Institutions: classification, due diligence and filing workflow under the Common Reporting Standard.
• DAC6 Reporting in Luxembourg: A Practical Guide to Mandatory Disclosure Rules: hallmarks, deadlines and intermediary duties for reportable cross-border arrangements.

Key Takeaways

• For a calendar-year group that did not elect, establish whether in 2024 it had Polish constituent entities and was covered by rules in another Member State equivalent to Directive 2022/2523, or by rules outside the EU corresponding to the OECD Model Rules; if so, Article 156(3) removes the first-year extensions and moves the 2025 GIR from 30 June to 31 March 2027, whether or not a foreign IIR reached a Polish constituent entity.
• Check every planned central-filing jurisdiction against the Article 133(6) list: a non-EU filer, or a filing in Estonia, Lithuania, Latvia, Malta or Slovakia, means a Polish GIR-1.
• Where the Article 133(4) exemption is used, diarise GLB-Z2 on the GIR date; the exemption does not remove the notification.
• Keep safe-harbour jurisdictions in the GLB-D1 plan, with explicit answers in fields 20 to 22 and zeros in the computation fields.
• Make the transitional CBCR safe harbour decision every year it is available; under Article 148(21), a year in scope that passes without the election bars it for later years.
• Test the JPK route for GIR-1 against the ministry’s XSD and error-code file, separately from the e-Deklaracje set-up for the returns.
• Leave GLB-D1 field 10 at No unless an amendment adding Article 153a has entered into force and applies to the tax year being filed.

Sources and References

• Ministry of Finance, Pytania i odpowiedzi dot. opodatkowania wyrównawczego (Q&A on top-up taxation, published 25 May 2026): podatki.gov.pl
• Act of 6 November 2024 on top-up taxation of constituent entities of international and domestic groups, Dz.U. 2024 poz. 1685 (Articles 1, 2, 4, 37, 128 to 137, 139, 147, 148, 154 to 156, 160): Dziennik Ustaw text via Sejm ELI
• Act of 13 February 2026 amending the Act on the exchange of tax information with other states and certain other acts, Dz.U. 2026 poz. 347 (Articles 1, 4, 7 and 13): Dziennik Ustaw text via Sejm ELI
• Regulation of the Minister of Finance and Economy of 24 April 2026 on the detailed scope of data in the information on top-up taxation, Dz.U. 2026 poz. 571: Sejm ELI record
• Regulation of the Minister of Finance and Economy of 25 September 2025 on the types of taxes, fees or non-tax budget receivables paid through the tax micro-account, Dz.U. 2025 poz. 1305 (annex, section IV: GLB-I1, GLB-D1, GLB-U1): Sejm ELI record
• Notice of the Minister of Finance and Economy of 5 June 2026 on the list of jurisdictions other than Poland that have implemented a qualified income inclusion rule or a qualified domestic top-up tax or meet the safe harbour requirements for a qualified domestic top-up tax, M.P. 2026 poz. 605: Sejm ELI record
• Ministry of Finance, GLOBE forms page (GLB-I1, GLB-D1, GLB-U1, GLB-Z1, GLB-Z2, GLB-Z3, GIR-1): podatki.gov.pl
• GLB-D1(1) XML schema (field definitions and receiving office): crd.gov.pl
• Ministry of Finance, Wymiana informacji podatkowych (GIR exchange and Article 133(4)): podatki.gov.pl
• Ministry of Finance, list of jurisdictions with a qualifying agreement on the exchange of top-up tax information under Article 133(6) (15 May 2026): gov.pl
• Ministry of Finance, Opinia GloBE: podatki.gov.pl
• OECD (2026), Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year): OECD PDF
• European Commission, Pillar 2 Global Minimum Tax Directive: New FAQ available (29 May 2026): taxation-customs.ec.europa.eu
• Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union: EUR-Lex
• Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9): EUR-Lex
• Government Legislation Centre, draft act amending the top-up taxation Act and certain other acts (UC90): legislacja.rcl.gov.pl

Before the 2027 Polish GloBE filings

For calendar-year groups that elected into 2024, 30 September 2026 is the statutory deadline for any 2024 GLB-I1 and GLB-D1 returns for which a Polish constituent entity is a taxpayer, together with payment of the tax shown. Groups that did not elect are working towards their first Polish GIR and returns, which for calendar-year groups fall in 2027 on dates the Act fixes by month count.

The document to produce before year-end is a first-tax-year memo for Poland: whether in 2024 the group was covered by another jurisdiction’s rules equivalent to Directive 2022/2523 or the OECD Model Rules while it had Polish constituent entities, whether the group sits in its initial period of activity, and where the GIR will be centrally filed. Those three answers select the 2025 GIR date, the notifications to file with it, and whether GIR-1 goes through the JPK interface or a GLB-Z2 covers the exemption.

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