A government draft amendment to the Polish PIT and CIT Acts, submitted to Parliament on 29 September 2026 as Parliamentary Paper No. 3149, proposes significant changes to two tax reliefs used by businesses. The robotics tax relief is to be extended until 2036, while the expansion relief is to be abolished from 2027.
The planned effective date is 1 January 2027, although the proposal is still under parliamentary review and may yet change.
The robotics tax relief is to be extended by 10 years
The draft provides for a ten-year extension of the robotics tax relief.
A deduction of up to 50% of eligible robotics costs would remain available until 2036, and for CIT taxpayers until the end of the tax year beginning in 2036.
The proposal also removes the DNSH condition introduced for purposes linked to the Recovery and Resilience Facility. Transitional rules are planned for costs incurred under the existing regime.
The treatment of qualifying costs is changing
The most important change concerns depreciable fixed assets and intangible assets.
Under the draft, only depreciation charges made in a given year would qualify for the relief, rather than the expenditure incurred to acquire the fixed asset or intangible asset itself.
The Ministry of Finance presents this as a clarification of its existing position. However, comments submitted during consultations indicate that market practice has not always been consistent, and the proposal to allow taxpayers to choose the method of settlement was rejected.
The tax benefit may be spread over time
For businesses, this means primarily a deferral of the tax benefit.
Where assets are depreciated, the relief would be claimed gradually together with depreciation charges. As a result, the tax benefit of an investment may be spread over several years rather than recognised when the expenditure is incurred.
Assets acquired before 1 January 2027 will require particular attention, especially as regards the treatment of depreciation charges falling after 2026.
The expansion relief is to be abolished
At the same time, the draft provides for the abolition of the expansion relief in both PIT and CIT.
Costs incurred before 1 January 2027 would remain subject to the current rules, including the requirement relating to growth in product sales revenue.
In practice, expenditure incurred from 2027 on trade fairs, promotion, certification and other activities currently covered by the expansion relief would no longer qualify for the additional deduction.
Investment and marketing budgets should be reviewed before the end of 2026
The proposal may directly affect spending decisions made at the turn of 2026 and 2027.
Before year-end, businesses should review:
The key conclusion is straightforward: the draft extends the robotics tax relief, but at the same time changes the way certain costs are recognised and abolishes the expansion relief. For investments planned for 2027, both the timing of expenditure and the method of tax settlement may therefore be critical.
Please contact us if your organisation requires support in assessing the impact of the proposed changes on planned investments and its 2027 tax budget.
We support businesses in analysing investment projects from the perspective of the robotics tax relief, transitional rules and the planned abolition of the expansion relief. We also help quantify the impact of the changes on tax budgets and expenditure timelines.
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