September 2026 brought four developments relevant to investors and companies doing business in Poland. The CJEU clarified the VAT treatment of transfer pricing adjustments, Poland confirmed a PLN 4,950 minimum wage for 2027, the State Labour Inspection issued its first interpretations on B2B relationships, and the Supreme Administrative Court clarified CIT bad debt relief for instalment payments.
How do transfer pricing adjustments affect VAT?
In its judgment of 13 May 2026 in Case C-603/24, the CJEU confirmed that a profitability adjustment does not automatically constitute payment for a service.
The decisive factor is whether a direct link exists between the payment and an identifiable supply supported by reciprocal obligations.
Even where no service exists, the adjustment may still change the price and taxable amount of an earlier transaction. Intra-group settlements therefore require a two-step analysis: first as possible consideration for a service and then as a potential price correction.
Read more: Transfer pricing adjustments and VAT in Poland – CJEU judgment
How will employment costs in Poland change in 2027?
From 1 January 2027, Poland’s minimum monthly wage for full-time employees will increase to PLN 4,950 gross, from PLN 4,806 in 2026. The minimum hourly rate for covered civil-law contracts will rise to PLN 32.30 gross.
Under the assumptions presented in the article, an employee would receive approximately PLN 3,703.93 net, while the employer’s total monthly cost would reach approximately PLN 5,963.77.
Overtime pay, night-work allowances, length-of-service allowances and jubilee awards remain excluded from the statutory minimum calculation.
For companies investing in Poland, the increase should therefore be reflected in 2027 employment budgets.
Read more: Minimum wage in Poland 2027
When can a B2B contract be treated as employment?
The first State Labour Inspection (PIP) interpretations confirm that the actual organisation of work takes priority over the title of the contract.
PIP examines factors including subordination, working time and place, independence, genuine substitution and business risk.
The right to reject an assignment does not by itself prove that a relationship is civil-law in nature. B2B cooperation may withstand scrutiny where the contractor genuinely operates independently and assumes business risk.
Read more: Mandate and B2B contracts in Poland: first PIP interpretations
How do instalments affect CIT bad debt relief?
In its judgment of 9 April 2026, case II FSK 1383/24, the Supreme Administrative Court ruled that a large enterprise owing money to an SME cannot use instalments to extend the statutory 60-day payment limit.
The limit applies separately to each instalment. Once the relevant deadline has expired, the creditor may reduce its taxable base, while the debtor must increase it.
The judgment does not concern VAT bad debt relief and does not impose a universal 60-day payment limit on all B2B transactions.
Read more: CIT bad debt relief in Poland: instalments and 60-day limit
For companies planning to invest in Poland, the September developments highlight the need to align contracts, accounting records and day-to-day business practice.
Read the full article here: Business Review Poland – September 2026
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