Business Review Poland – September 2026
5 October 2026
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September 2026 brought important tax and employment developments for companies operating in Poland. The CJEU clarified the VAT treatment of transfer pricing adjustments, Poland confirmed a PLN 4,950 minimum wage for 2027, the State Labour Inspection issued its first interpretations on B2B and mandate contracts, and the Supreme Administrative Court ruled on CIT bad debt relief for instalment payments.
In this article:
How should transfer pricing adjustments be treated for VAT?
In its judgment of 13 May 2026 in Case C-603/24, the CJEU held that a profitability adjustment does not automatically constitute consideration for a service.
The decisive issue is whether there is a direct link between the payment and an identifiable supply supported by reciprocal obligations. Even where no service exists, an adjustment may still affect the price and taxable amount of an earlier supply.
Intra-group settlements should therefore be tested first as possible consideration for a service and then as a potential price adjustment.
Read more: Transfer pricing adjustments and VAT in Poland – CJEU judgment
What will Poland’s minimum wage be in 2027?
From 1 January 2027, the minimum monthly wage for a full-time employee will increase to PLN 4,950 gross, compared with PLN 4,806 in 2026. The minimum hourly rate for covered civil-law contracts will rise to PLN 32.30 gross.
Under the assumptions used in the article, an employee would receive approximately PLN 3,703.93 net, while the employer’s total monthly cost would reach around PLN 5,963.77.
Overtime pay, night-work allowances, length-of-service allowances and jubilee awards remain excluded when calculating the statutory minimum.
Read more: Minimum wage in Poland 2027
When can B2B cooperation become an employment relationship?
The first interpretations issued by the State Labour Inspection (PIP) confirm that the actual organisation of work matters more than the contract’s title.
PIP examines factors including subordination, working time and place, independence, genuine substitution and business risk. The ability to reject an assignment does not by itself establish a civil-law relationship.
A favourable interpretation binds PIP only in relation to the facts described in the application. If actual working practices differ, the company may still face risks during an inspection.
Read more: Mandate and B2B contracts in Poland: first PIP interpretations
How do instalments affect CIT bad debt relief?
In its judgment of 9 April 2026, case II FSK 1383/24, the Supreme Administrative Court ruled that when a large enterprise owes an SME, dividing a payment into instalments cannot extend the statutory 60-day payment limit. The limit applies to each instalment.
After the relevant deadline, the creditor may reduce its taxable base while the debtor must increase it. The ruling does not concern VAT bad debt relief and does not establish a universal 60-day limit for all B2B transactions.
Read more: CIT bad debt relief in Poland: instalments and 60-day limit
Overall, the September developments reinforce the importance of consistency between contract wording, accounting records and actual business practices for companies operating in Poland.
Read the full article here:
If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.
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