The government isn't giving up on the digital tax. We know how much Google and Microsoft will have to pay.

• The Ministry of Digital Affairs is not giving up on plans to subject digital giants to a new tax .
• According to the CIS findings, the tax is to amount to 3% of consolidated company revenues and will apply to entities that generate global revenues exceeding EUR 750 million.
• It will cover: digital interface services, targeted digital advertising, and the sale or licensing of data about users and their activities on platforms.
• The Ministry of Digital Affairs expects that the new levy could provide the budget with approximately PLN 1.7 billion in 2027, and as much as PLN 3 billion in 2030. The money is to be allocated to innovation and media development.

The Ministry of Digital Affairs has prepared preliminary guidelines for work on a bill introducing a digital tax for the largest technology companies. The intention is to force companies to settle their taxes in Poland. According to the ministry, they currently do not pay tax proportionally to the revenue they generate from operating in the Polish market.

"The digital tax should be dignified for the state"

Examples? Facebook's Polish subsidiary had PLN 1.82 billion in revenue in Poland in 2024, but because its income was only PLN 42.5 million, it paid PLN 10.6 million in taxes.

"That's nothing. They haven't paid this [Chinese e-commerce platform – editor's note] a penny," a senior MC official tells us.

In recent months, the head of the ministry, Deputy Prime Minister Krzysztof Gawkowski, has repeatedly emphasized that he would like to equalize the tax disproportions between Polish and foreign entities.

"In my opinion, a digital tax is a dignified solution for the state . We must take into account that for years various large companies have been profiting from Poland, offering their services under the guise of providing something for free, thus creating monopolies that later generate huge profits," he said in an interview with WNP.

What will be the tax rate for digital giants?

According to the documents we've seen, the Ministry of Finance wants to introduce a 3% tax on consolidated revenues . This would apply to companies generating global revenues exceeding €750 million. The ministry states that it is modeling the tax on solutions implemented in France, Spain, and the United Kingdom.

According to the MC proposal, companies subject to taxation will be obliged to report actual income related to services provided in Poland or related to real estate or goods located in Poland.

Companies' reporting will be based on data they already possess (e.g., IP addresses of service users). This will be used to conduct a "reasonable assumption" test—a user will be deemed a resident of a given country if the information collected indicates such a likelihood. This will eliminate the need to collect additional customer data.

What is to be taxed?

The Ministry has decided that three types of activities will be subject to taxation .

• First, digital interface services. These are software (e.g., a platform, an application) that allows users to interact with each other and exchange information, goods, or services. Examples include marketplaces, resource-sharing applications (e.g., taxi services), and social media.
• Secondly, targeted digital advertising services. Profiling is a service that displays advertisements tailored to a specific user based on data collected about them. Examples include social media and search engine advertising (SEM).
• Third: data transfer services . These are services that involve selling or licensing data about users and their activities on platforms (e.g., interests, shopping habits, location). This data is used for marketing and service improvement purposes, among other things.

As the ministry declares, it is crucial that the new tax forces international corporations to pay taxes honestly, but also protects companies that actually pay CIT due in Poland.

What services will be excluded from the digital tax?

The ministry also plans to introduce exemptions. These will include:

• Digital intermediation services where the main purpose is to provide users with digital content (e.g. computer programs, games, applications) or to provide them with communication or payment services (i.e. digital interfaces where users do not play a key role in creating value for the entity providing the interface).
• Regulated financial services provided by regulated financial entities (e.g. banking applications).
• The sale of goods or services online through the website of their supplier , where the supplier does not act as an intermediary (e.g. e-commerce related to retail activities).

What proposals did the Ministry of Digital Affairs have on the table?

As we have learned, the ministry's proposal was developed on the basis of an expert opinion commissioned by the Ministry of Digital Affairs from the Instrat Foundation.

The Foundation proposed two tax concepts – broad and narrow.

• In the narrow scenario, only revenues from targeted digital advertising would be taxed . Depending on the rate, these revenues would contribute to the state budget in the first year of implementation:

- PLN 482 million assuming 5%

- PLN 578 million at a rate of 6%.

- PLN 722 million at a rate of 7.5%.

In 2030, these amounts would amount to PLN 772 million (5%), PLN 927 million (6%) and PLN 1.2 billion (7.5%), respectively.

• The broad concept proposed taxing not only advertising revenue but also digital interface access. The Instrat Foundation proposed lower rates: 3%, 4.5%, or 6%. In 2027, such a tax would generate PLN 1.7 billion, PLN 2.6 billion, and PLN 3.4 billion, respectively, for the state budget.

According to the findings of the CIS, the Ministry of Digital Affairs decided on the broad variant, but at the lowest rate.

Where will the money from the digital tax go?

The ministry would like to allocate the tax revenues to the development of Polish technologies and innovation, as well as support for quality media. "They are the ones who have lost the most from the takeover of the advertising market by big tech," we read in the justification for the proposal, which the ministry forwarded to interested organizations.

The ministry presented the proposal on Wednesday, August 13th, during a meeting with market representatives. The ministry states that the presented assumptions are only a preliminary step in further legislative work. However, the minister emphasizes that the draft bill is expected to be ready by the end of this year.