Tax overhaul 2027 - what is the Ministry of Finance planning?
The Ministry of Finance has presented a draft bill that could fundamentally change the rules of taxation in Poland from 1 January 2027. The proposal amends three key pieces of legislation - the Personal Income Tax Act (PIT), the Corporate Income Tax Act (CIT) and the Flat-Rate Income Tax Act. The draft, presented in mid-March 2026, is currently at the consultation stage, which means its final shape may still change.
The planned changes concern three main areas: the housing relief on the sale of property, the flat-rate tax rates for single-person service businesses, and the conditions for using the IP Box preference. Each of these changes has significant financial and legal consequences for taxpayers - both individuals and business owners. It is worth analysing the planned rules now so that you can prepare properly for the new tax environment.
The Ministry of Finance's stated aim is to tighten the tax system and curb the abuse of tax preferences. In practice, however, this means that hundreds of thousands of taxpayers will have to revise their existing tax optimisation strategies.
Housing relief with a three-year waiting period
One of the most important planned changes is a modification to the rules for using the housing relief. Currently, a taxpayer who sells a property within five years of acquiring it can avoid paying 19% income tax if they use the proceeds for their own housing purposes. This solution has for years been one of the most frequently used exemptions in PIT.
Under the draft amendment, the housing relief will not be abolished, but it can be used again only after three years have passed since the previous use of this exemption. The Ministry of Finance argues that the current rules allow repeated, investment-driven sales of property without any tax burden, which runs contrary to the original purpose of the relief.
In practice, this change will mainly affect people who regularly buy and sell property, using the profits to purchase further flats or houses. The three-year waiting period means transactions on the property market will need to be planned more carefully. Anyone planning to sell a property in the coming months should consider whether it is worth bringing the transaction forward before the new rules potentially come into force.
Who will be most affected by the restrictions on the housing relief?
The changes will be felt especially by:
- Property investors - people who regularly buy and sell flats for profit
- People who move frequently - taxpayers who often change their place of residence for various personal reasons
- Heirs of property - people who sell inherited flats to finance their own housing needs
- Individual developers - private individuals who run a business of finishing and reselling units
Higher flat-rate tax for single-person service businesses
The draft provides for a significant increase in the flat-rate tax rates on recorded revenue for people running a single-person business in the services sector who do not employ staff. The current rate of 8.5% is to be raised to 15% for revenue exceeding PLN 100,000 per year. This is almost a doubling of the tax burden.
The same 15% rate would also apply to rental income from related parties where that amount exceeds PLN 100,000 per year. An even higher 17% flat rate has been proposed for income from the rental or lease of intellectual property, excluding works protected by copyright.
This change appears to be aimed at a business model popular among freelancers and self-employed specialists - particularly in IT, consulting and professional services. Running a single-person business on the flat-rate tax, they have so far enjoyed relatively low taxation. Employing even one member of staff would allow them to avoid the higher rate, which suggests that the regulation also aims to encourage the creation of new jobs.
IP Box with new conditions - the end of the golden age for programmers?
Particularly significant changes concern the IP Box relief (Innovation Box), introduced into the Polish tax system in 2019. This mechanism allows income from qualified intellectual property rights to be taxed at a preferential rate of just 5% instead of the standard PIT rates (12% and 32%) or CIT rate (19%). Programmers, software developers and other technology specialists have used it extensively.
The Ministry of Finance's draft does not abolish the IP Box relief, but it introduces additional conditions for its use. A business owner wishing to benefit from the preferential 5% rate will have to meet one of two requirements:
- Employ at least three staff for at least 300 days in the tax year, or
- Document cooperation with individuals paid at a specified minimum level of remuneration
For many single-person IT businesses that have so far used the IP Box as self-employed specialists, meeting these conditions will be difficult or economically unviable. The requirement to employ three people generates not only salary costs, but also burdens related to Social Insurance Institution (ZUS) contributions, HR administration and management. In practice, this change could mean that thousands of programmers and IT specialists lose access to the preferential 5% rate, significantly increasing their tax burden.
How to prepare for the 2027 tax changes
Although the draft bill is only at the consultation stage, the scale of the proposed changes calls for preparing your tax strategy in advance. Taxpayers who may be affected by the new rules should take concrete action now.
Recommended steps
First of all, it is worth carrying out an audit of your current tax situation - assessing which of the planned changes may affect your business or planned transactions. People using the flat-rate tax should analyse whether switching to the general rules or the flat 19% tax would be more beneficial once the new rates come into force.
Business owners using the IP Box relief should consider reorganising their employment structure or their model of working with subcontractors in order to meet the new conditions of the preference. Those planning to sell property using the housing relief should discuss the timetable of their transactions with a tax adviser.
It is also crucial to follow the progress of the legislation - the draft may change significantly during further parliamentary work. We will probably learn the final shape of the rules in the second half of 2026.
Need legal support? Contact us
The planned tax changes are complex and may require an individual legal analysis tailored to your specific situation. Interpreting the rules on your own carries a risk of costly mistakes. Our firm offers comprehensive advice on tax law, tax optimisation and planning property transactions.
Do not wait for the rules to come into force - prepare now. Contact our specialists to discuss the impact of the planned changes on your tax situation and to work out the best strategy for 2027 together. An initial consultation will help you assess the scale of the potential changes and plan the necessary steps.
Have a question about this?
The first consultation is free - let us talk about your situation.
