• On February 21, 2025, Finance Minister Andrzej Domański met with business representatives and tax advisors as part of a consultation on proposals to adapt the research and development (R&D) tax incentive to the GloBE system.
• The discussion confirmed the issue's importance from taxpayers’ perspective.
• The Ministry stated that it would continue the dialogue to better understand the expectations of stakeholders regarding the shape of target solutions.

The discussion focused on three alternative directions for changes in the regulations, namely:

• a cash refund of the unused R&D tax incentive deducted from the tax base;
• a cash refund of the unused R&D tax credit, deducted from the tax (R&D Tax Credit);
• a division of the current R&D tax incentive into two components - a payroll cost component settled outside of the CIT (modelled on the mechanism of the innovative employees tax relief) and a material cost component settled within the CIT.

Minister Andrzej Domański emphasized the Ministry's commitment to developing a solution that maximises Poland's international competitiveness and investment attractiveness.

Representatives of the Ministry stressed that these directions serve only as an introduction to further discussion. At the same time, they have expressed their openness to other proposals. The intentions of the Ministry expressed during the meeting and shared by its participants specifically concerned:

• striving to maintain the neutrality of the proposed changes, both from the point of view of the business (subject to the top-up taxation as well as other beneficiaries of the R&D tax relief) and the state budget; consultation participants mutually acknowledged the necessity of reconciling these proposals and the importance of maintaining the R&D tax relief in the tax system to sustain the competitiveness of the Polish economy;  
• ensuring that potential new solutions comply with the requirements set out within the BEPS 2.0 framework; and
• the necessity of implementing the proposed changes within a short time frame, i.e. from January 1, 2026, while also considering the possibility of applying them to the current year, 2025.

Among the proposals made by business representatives, one particularly noteworthy suggestion was the introduction of several parallel solutions, which would allow taxpayers to choose the option most favourable for them (adequate to their situation).

Based on the comments and proposals raised during the meeting, the Ministry of Finance will present detailed proposals of solutions for further discussion on the issue.