In August 2025, the obligation to publish Information on the Implemented Tax Strategy was removed from the Polish tax system. For several years, this document aimed to increase transparency in tax activities among the largest enterprises. The change, introduced as part of the government’s “Support for Business and Deregulation” programme, raises questions about the future of tax transparency and public awareness regarding public finance.
1. What Was the Tax Strategy?
The Information on the Implemented Tax Strategy (Article 27c of the Corporate Income Tax Act, “CIT”), commonly referred to as the tax strategy, was a document published annually on websites by the largest taxpayers - those with annual revenues exceeding EUR50 million - and by tax capital groups. According to data from the Ministry of Finance, in 2023 there were nearly 4,300 such entities 1.
The Information on the Implemented Tax Strategy included both data already known to the tax administration from submitted declarations or tax forms (e.g., transactions with related entities, reported tax schemes), as well as new information regarding internal procedures and tax processes used to fulfil tax obligations, which was previously unavailable to the administration and the public.
2. Abolition of the Obligation – What Has Changed?
In early August 2025, President Andrzej Duda signed the Act of June 25, 2025, which amended the Corporate Income Tax Act (Journal of Laws 2025, item 1074), repealing Article 27c and thus abolishing the obligation to prepare and publish the Information on the Implemented Tax Strategy 1. According to the amendment, all obligations regarding tax strategies whose execution deadline fall after August 6, 2025, no longer apply to taxpayers. In practice, taxpayers whose tax year aligns with the calendar year will not need to prepare or publish the document for 2024 and subsequent years.
Importantly, according to Article 2 of the Act, all ongoing proceedings for failure to fulfil the obligation are discontinued, and no new proceedings will be initiated:
If the deadline referred to in Article 27c(4) of the amended Act expired before the entry into force of this Act, no proceedings shall be initiated to impose a financial penalty referred to in Article 27c(8) of the amended Act, and any initiated proceedings shall be discontinued.
Repeal of Article 27c of the CIT Act is equivalent to abolishing the obligation to make information available on the website for individual years (Article 27c(6)). Thus, the obligation to ensure access to information posted on the website for previous years has also been removed. Although the repealing Act does not address the maintenance of documents for previous years, the legislator’s intention is clearly presented in the justification to the Act:
Repeal of Article 27c of the CIT Act will be equivalent to abolishing the obligation to make information available on the website for individual years (Article 27c(6)). According to the applicable regulations, information once posted on the website must be available to interested parties for subsequent years. Thus, after the entry into force of the Act, the obligation to ensure access to information posted on the website for previous years will also be abolished.
3. Reflections After Abolition – What About Transparency?
From the taxpayers’ perspective, the abolition of this obligation is a beneficial simplification, as the requirement to publish the Information was criticised for several reasons:
- The document's non-standardised format limited its informational value.
- The lack of clear guidelines caused interpretative difficulties and diverse approaches.
- There was limited understanding of the purpose of the obligation and how the information provided would be used.
Nevertheless, the manner and timing of the change are surprising for two reasons:
- Withdrawal of the obligation contradicts global trends of increasing tax transparency and building social and business awareness regarding taxes.
- The Ministry of Finance initiated public pre-consultations on reformulating the obligation, indicating specific issues that require changes.
4. What’s Next?
Although the obligation to publish Information on the Implemented Tax Strategy has been abolished, the topic should not disappear from companies’ agendas. Voluntary disclosure of information about tax burdens and the company’s actual contribution to the state budget extends beyond merely meeting legal requirements. It is a proactive action addressing the needs of various stakeholders - investors, customers, employees, regulatory bodies, and the broader public - for a fuller picture of corporate responsibility.
In the context of the growing importance of ESG (Environmental, Social, Governance) criteria and new regulations such as the Corporate Sustainability Reporting Directive (CSRD), tax issues are increasingly seen as an integral part of corporate governance and the company’s contribution to society. Companies that proactively communicate their approach to taxes demonstrate maturity in management and social responsibility, which can translate into many aspects of business operations.
It is recommended that tax information be included in other public disclosures, such as stock exchange reports, annual reports, and CSRD or ESG reports. Additionally, taxpayers may continue with the existing format and publish a separate annual tax report, enriching it with a calculation of the total tax contribution.
Tax management
Despite the Ministry of Finance’s step back on tax transparency, the Polish Ministry of Finance is following global trends by placing increasing emphasis on structured tax management (tax governance) and building a mature tax function (tax control framework, or as per the Ministry: Internal Tax Supervision Framework. Supporting these activities, detailed guidelines for taxpayers have been developed as part of public consultations—not only for those interested in the Cooperative Compliance Programme, but for all taxpayers.
We are happy to discuss the process of building a mature and effective tax function, using materials prepared by the Ministry of Finance, best practices, and our experience. Feel free to contact us.
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