On January 1, 2025, the so-called “Top-up Tax” law came into effect, introducing a new type of income taxation. This is part of the global tax reform known as “Pillar II,” aimed at eliminating profit shifting to low-tax jurisdictions.

New regulations will apply to companies, branches, and establishments that are part of an international or domestic capital group with global annual revenues of at least EUR 750 million in at least 2 of the last 4 years.

Three types of top-up taxes are expected to be introduced:

– Global Top-up Tax – This will be imposed on parent entities. The obligation to pay this tax in Poland may arise if the headquarters is based in Poland, while subsidiaries operate in jurisdictions where the effective tax rate is lower than 15%.

– Domestic Top-up Tax – The obligation to pay this tax in Poland may arise if the effective tax rate of subsidiaries operating in Poland does not exceed 15%.

– Undertaxed Profits Rule (UTPR) – This tax may be imposed on subsidiaries if the parent entity operates in a country that has not implemented “Pillar II” regulations.

The purpose of this event is to introduce participants to the concept of the Global Minimum Tax (Top-up Tax), which will apply to companies within large capital groups. During the webinar, the fundamental principles of the new tax system and the obligations for taxpayers arising from its implementation will be discussed.

This webinar is primarily intended for individuals responsible for accounting and tax matters in companies that are part of large capital groups, as well as for anyone interested in international tax law.

More information and registration here.