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Good to know Changes to R&D relief in the context of global minimum tax

Changes to R&D relief in the context of global minimum tax

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​​​​​​​​by Dominika Górska, Magdalena Skurowska

5 March 2025


The Ministry of Finance held consultations on 21 February 2025 on how to modify the research and development relief in the context of legislation on top-up tax. 

The consultations and modifications aim at increasing Poland’s investment attractiveness which may be adversely affected by the 15% global minimum tax (GloBE). 

R&D relief – directions of e​​volution in view of global minimum tax: 


  1. Option 1: extended cash refund of unused R&D relief deductible from the taxable base (within maximum 4 years of earning the right to the refund) to include all taxpayers, without fundamental changes to the relief mechanism itself. 
  2. Option 2: R&D Tax Credit – revised relief mechanism to make it deductible from the tax itself instead of the taxable base. Unused part of the relief would be refunded.
  3. Option 3: Break the relief into two components: one covering personnel expenses and the other for other expenses. In this option, personnel expenses would be pulled out of the R&D eligible costs and made eligible for a separate relief accounted for in a way similar to the relief for innovative employees. 

The Ministry of Finance has emphasised that these are just proposals, and the final solution is still being worked on. The Ministry has announced the effective date for the revised regulations to be 1 January 2026.

Although the final shape of the legislation is not yet known, businesses are certain to face major changes when it comes to accounting for the R&D relief. It is worth consulting a tax adviser to make full use of the available options and avoid potential risks. Our experts will help you to understand the changes, assess benefits for your company and implement the best solution effectively. You are welcome to contact us​.​

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