Minimalny podatek dochodowy jako instytucja komplementarna wobec globalnego minimalnego podatku dochodowego
Minimum Income Tax as a Complementary Institution Towards Global Minimum Income Tax

Summary/Abstract: The article examines the legitimacy of the parallel application in Poland, starting in 2025, of two minimum taxes, the GloBE and the minimum income tax (Article 24ca of the CIT Act). A comparative doctrinal analysis and historical analysis shows that despite their similar names, these instruments differ in design, purpose, and tax base — GloBE applies to income, while the minimum income tax applies to gross income. GloBE aims to reduce tax competition, whereas the minimum income tax targets tax avoidance. The author concludes that the two taxes are complementary and that Poland should maintain the minimum income tax despite the implementation of GloBE.

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