2026-10-12
Possible change of a company’s tax office in Poland from 2027 – what to check before October 15th?
By 15th of October 2026, some taxpayers might be transferred to a different Polish tax office as from 1 January 2027. If so, theymust notify the head of their currently competent tax office. This requirement covers transfers “up” to a specialised tax office, transfers between specialised offices, and transfers “down” to a local tax office. Whether a transfer is required may depend on the taxpayer’s sales revenue. However, comparing the latest annual figures with the current threshold is not enough. Taxpayers must also establish whether they meet the conditions for coming under a particular office’s jurisdiction or for leaving it. For the First Mazovian Tax Office in Warsaw, transitional provisions must also be considered. The rules below concern tax office jurisdiction determined by reference to revenue.
What revenue thresholds apply?
Since 1 January 2026, the revenue threshold for the First Mazovian Tax Office in Warsaw has been EUR 100 million, up from EUR 50 million. The higher threshold also applies when assessing whether a taxpayer must transfer to that office from 2027.
The revenue-based allocation is as follows:
| Net sales revenue | Tax office responsible under the revenue criterion |
| Below EUR 3 million | Generally, the local tax office |
| From EUR 3 million up to and including EUR 100 million | The regional specialised tax office responsible for the area of the taxpayer’s registered office |
| Above EUR 100 million | The First Mazovian Tax Office in Warsaw, regardless of the location of the taxpayer’s registered office |
These bands do not, on their own, determine when a transfer takes effect. In particular, a fall in revenue below a threshold does not automatically result in a transfer out of the current office the following year.
Which years should be reviewed for a transfer from 2027?
To assess whether a taxpayer must come under a particular tax office’s jurisdiction as from 1 January 2027, the relevant figures are those for the tax year ending in 2025. Meeting the revenue criterion in a single tax year may therefore be sufficient to trigger a transfer “up” (from local to a specialised tax office).
On the other hand, leaving a specialised tax office’s jurisdiction generally requires the taxpayer to fall outside the relevant revenue criterion for two consecutive tax years. For companies whose tax year is a calendar year, the years to review for a potential transfer from 1 January 2027 are therefore 2024 and 2025.
In practice:
- a company transferring to a specialised tax office reviews its revenue for the tax year ending in 2025;
- a company assessing whether it must leave a specialised tax office reviews two consecutive tax years – 2024 and 2025 (if its tax year follows the calendar year).
A company currently handled by a regional specialised tax office is therefore not necessarily required to return to a local tax office simply because its revenue fell below EUR 3 million in 2025. It must also check whether its revenue was below the applicable threshold in 2024.
Which revenue figure should be compared with the threshold?
For Polish companies, the starting point is net revenue from sales of goods, products and services reported in the financial statements. The corporate income tax (CIT) return should be used only where this figure cannot be established from the financial statements.
A company should therefore not automatically use its total revenue for tax purposes. It must identify the relevant revenue figure and compare it with the applicable threshold.
Thresholds expressed in euros are converted into Polish zlotys using the exchange rate from the last business day of the relevant tax year. For companies whose tax year follows the calendar year, the figures are:
| Year | EUR/PLN exchange rate | PLN equivalent of EUR 3 million (threshold for local/specialised tax office) | PLN equivalent of EUR 100 million (threshold for the First Mazovian Tax Office) |
| 2024 | 4.2730 | PLN 12,819,000 | PLN 213,650,000 – the EUR 50 million threshold |
| 2025 | 4.2267 | PLN 12,680,100 | PLN 422,670,000 – the EUR 100 million threshold |
As mentioned before, the 2024 figures are relevant only when assessing the conditions for leaving a specialised tax office. The 2025 figures are relevant both to transfers “in” and transfers “out” of an office’s jurisdiction.
To determine whether a transfer to the First Mazovian Tax Office is required as from 1 January 2027, revenue for the tax year ending in 2025 must be compared with the new EUR 100 million threshold. For the 2025 calendar year, this is PLN 422,670,000. The historical EUR 50 million threshold shown in the table is not the current threshold for transferring to that office.
Even where sales are settled in euros, the comparison must be made in Polish zlotys using the correctly converted PLN-threshold.
When is a transfer mandatory? Examples
The examples below concern companies whose tax year follows the calendar year and whose tax office jurisdiction is determined by revenue.
Transfer to a regional specialised tax office
A company currently handled by an local tax office reported net sales revenue of PLN 16 million in 2025. It therefore exceeded the EUR 3 million threshold, equivalent to PLN 12,680,100. As from 1 January 2027, it will therefore be handled by the regional specialised tax office responsible for its registered office. It must notify the head of its current tax office by 15th of October 2026.
Transfer back to a local tax office
A company currently handled by a regional specialised tax office reported net sales revenue of PLN 11 million in 2024 and PLN 12 million in 2025.
Its revenue was below the applicable PLN equivalent of EUR 3 million in both years. It therefore meets the revenue-based conditions for returning to a local tax office as from 1 January 2027. The notification must be submitted to the head of its current (specialised) tax office.
Transfer to the First Mazovian Tax Office
A company handled by a regional specialised tax office reported net sales revenue of PLN 440 million in 2025. It exceeded the EUR 100 million threshold, equivalent to PLN 422,670,000.
Starting 1 January 2027, it will come under the jurisdiction of the Head of the First Mazovian Tax Office in Warsaw. It must notify the head of its current tax office by 15th of October 2026.
Revenue of EUR 50–100 million – must taxpayers leave the First Mazovian Tax Office?
The increase in the threshold to EUR 100 million does not mean that every taxpayer with revenue in the EUR 50–100 million range must leave the First Mazovian Tax Office.
Taxpayers that remain under its jurisdiction by virtue of the transitional provisions may continue to be handled by that office. Revenue below the new threshold does not, in itself, require them to transfer.
They may, however, choose to move to the regional specialised tax office responsible for their registered office. To do so, they must submit a statement opting out of continued administration by the First Mazovian Tax Office.
If the statement is submitted to the Head of the First Mazovian Tax Office in Warsaw by 15th of October 2026, the transfer will take effect on 1 January 2027.
In this case, the statement reflects the taxpayer’s choice. It should be distinguished from the mandatory notification required when the conditions for a compulsory transfer are met.
Who should receive the notification?
A notification of a change in tax office jurisdiction must be submitted to the head of the taxpayer’s current tax office. It should not be sent to the head of the office that will take over from 2027.
This rule applies to transfers to a specialised tax office, transfers between specialised offices, and transfers back to a local tax office.
A statement opting out of continued administration by the First Mazovian Tax Office must likewise be submitted to the head of that office.
What should companies check before the deadline?
Before 15th of October 2026, a company should establish:
- Its net sales revenue for the tax year ending in 2025 and, when assessing a transfer out of a specialised tax office, for the preceding tax year as well.
- Whether comparing those figures with the applicable thresholds requires a transfer from 1 January 2027.
- Whether its current tax office jurisdiction is based on revenue, or whether it remains with the First Mazovian Tax Office under the transitional provisions.
- Whether it must submit a mandatory notification or wishes to exercise the option to leave the First Mazovian Tax Office voluntarily.
A correct assessment requires both the relevant revenue figures and the appropriate review period. Particular care is needed to distinguish the conditions for (i) coming under an office’s jurisdiction from those for (ii) leaving it, and – in case of bigger companies – to establish whether the transitional provisions for the First Mazovian Tax Office apply.
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