Introduction of a digital tax on the so-called Big Tech

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In March 2025, the Minister of Digitalisation officially announced the start of work on the introduction of a digital tax in Poland. As announced, the tax would be levied on the largest global technology companies operating in the Polish market. These currently generate significant revenues from Polish users and, at the same time, do not pay proportional taxes to the state budget.

Scope and objectives of the digital tax

The proposed digital tax would mainly impinge upon the activities of several international technology giants, i.e. Big Tech, and  would primarily affect certain global digital platforms operating within the Polish market and generating significant revenues from Polish users. The scope of entities subject to the digital tax would also include technology companies that can optimise their tax burden due to the specific nature of their business.

The initiative to tax digital services in Poland is not new. The first discussions on the topic began in 2018, in response to the European Commission’s proposal for a harmonised regulation at the Community level. Later, a draft law was presented, which provided for the introduction of a tax on the revenues of technology companies with global revenues exceeding €750 million per year. However, the project did not gain support and was not the subject of further legislative action.

On 19 March 2025, NGOs and publishers sent an open letter to the Minister of Digitalisation, Mr. Krzysztof Gawkowski, and the Minister of Finance, Mr. Andrzej Domański, highlighting the risks posed by the dominance of global platforms and their business strategies, and calling for broad public consultations to develop solutions that will increase Big Tech’s contribution to covering the social and economic costs of its activities. They propose the creation of a fund to finance, among other issues, research, countering technological threats, combating fake news and disinformation in the media, and digital education for the public (https://centrumcyfrowe.pl/czytelnia/w-strone-cyfrowej-suwerennosci-apel-do-rzadu/ – available on 7th April 2025).

Allocation of tax revenue

It is estimated that the introduction of the digital tax could generate around PLN 3-4 billion per year for the state budget. The Ministry of Digitalisation has announced that the funds raised by the digital tax will be used for specific purposes to support the country’s digital transformation. Accordingly, a significant part of the revenue would be used to support the development of the national technology sector, including start-ups and IT companies, which could help increase the competitiveness of Polish companies on the international stage. The Ministry also plans to fund research and development in the field of new technologies, with a particular focus on the development of artificial intelligence technologies within the nation.

Divisions in the government

Although the Ministry of Digitalisation is pushing the idea of a digital tax, the project faces resistance within the government. The Ministry of Finance issued a statement clearly stating that it is not currently working on legislation in this area. Prime Minister Donald Tusk, in turn, took an intermediate position, announcing the preparation of a draft law, but without explicitly stating the date and final decision on its implementation.

The equalisation levy and the new digital tax

The proposed digital tax should be seen in the context of the existing global equalisation tax, implemented under EU Directive 2022/2523. These rules, which have been in force in Poland since 1 January 2025 (with an option to apply from 1 January 2024), apply to companies with global revenues exceeding €750 million and is intended to ensure that these entities pay a minimum effective tax rate of 15% to the state. The main objective is to limit the erosion of the tax base and the shifting of profits to more favourable jurisdictions. This mechanism has already influenced the strategy of some global companies, which have announced an increase in investments in Poland, which may result in an increase in their tax liabilities.

The planned introduction of a national digital tax raises questions about its real fiscal impact. Examples from other countries show that the cost of such a tax is often passed on to business partners, which may result in higher prices for digital services for Poland’s consumers and businesses.

Summary

The introduction of a digital tax in Poland is currently at the conceptual stage, and its final form and implementation date are uncertain. The lack of a coherent position within the government, as well as international pressure, may delay or even block the legislative process. It will be crucial to find a model that benefits the state budget but does not overburden Polish entrepreneurs and consumers. The introduction of a digital tax would also have a significant impact on the digital and innovation ecosystem in Poland. It will be a major challenge to consider the interaction between this tax and the existing globalisation tax to determine the actual tax burden on technology companies and the potential impact on Poland’s economy and consumers. NGOs and the media are calling for broad public consultation and inter-ministerial cooperation to develop optimal solutions.