New Tax Regulations: Crypto-Asset Reporting and Changes for International Groups

The President of the Republic of Poland has signed an amendment to the Act on the Exchange of Tax Information with Other Countries and Certain Other Acts, which implements two European Union directives into Polish law: DAC8 and DAC9. The new regulations aim to increase the transparency of the tax system and more effectively combat abuses in rapidly developing areas of the economy, such as the crypto-asset market and the operations of multinational corporate groups. As a result, additional obligations will arise for crypto-asset service providers, and the scope of automatic exchange of tax information will be significantly expanded.

Reporting and Exchange of Information on Crypto-Assets

One of the key elements of the DAC8 directive is the introduction of mandatory reporting and automatic exchange of information regarding transactions involving crypto-assets.

Under the new regulations, information about such transactions will be provided by intermediaries participating in their execution and then automatically exchanged between the tax administrations of individual countries.

The solution aims to limit phenomena such as:

tax fraud,
tax evasion,
tax avoidance in the area of digital assets.

Greater transparency in this area is intended to address tax challenges related to the global nature of the crypto-asset market.

Top-Up Taxation and Centralised Filing of Returns

The second directive being implemented – DAC9 – concerns the exchange of information related to top-up taxation (global minimum tax). These regulations are linked to the GloBE Directive of 2022, which introduced a minimum level of taxation for large multinational groups.

DAC9 provides for the possibility of centralised filing of top-up tax returns. In practice, this means that:

a tax return may be filed by one company from the group operating within the European Union,
other entities belonging to the same group in the EU are exempt from submitting similar returns.

The directive also establishes a standardised tax return template, developed on the basis of OECD guidelines, which will also be applied in Poland.

Global Tax Cooperation and Additional Reporting Obligations

The new act also introduces solutions enabling Poland to participate in the global system of tax information exchange, covering not only EU Member States but also OECD countries.

In addition, the provisions expand the scope of exchanged information to include, among others:

cross-border tax rulings concerning individuals, where the value of the transaction exceeds EUR 1.5 million,
income from real estate owned by non-residents.

Entry into Force of the New Regulations

The act will enter into force the day after its publication. However, it provides that crypto-asset service providers will also be required to report transactions carried out from the beginning of 2026, i.e. even before the formal entry into force of the regulations.

The new rules will also apply to the exchange of information on cross-border tax rulings concerning individuals issued after 31 December 2025.

The first exchange of data under the new system – covering both crypto-assets and the updated CRS standard – is planned for 2027 and will concern information for 2026 as the first reporting period.