Poland 2027 3% Digital Services Tax Bill

Poland has published draft legislation introducing a 3% tax on certain digital revenues from 1 January 2027

The draft bill, released by the Ministry of Digital Affairs, would apply to the world’s largest digital businesses generating significant revenues from Polish users. The government estimates the measure could raise PLN 31.7 billion (€7.4 billion) over the next decade.

Which digital services are covered?

The proposed 3% DST would apply to revenues from:

• Digital advertising targeted at users in Poland
• Online platforms and marketplaces that enable user interaction or facilitate transactions
• The sale or licensing of user data collected through digital platforms

The legislation deliberately focuses on digital services rather than specific technologies, allowing it to capture future business models, including AI-driven digital services.

Excluded activities include direct online sales where the supplier is not acting as an intermediary, payment and communications services, regulated financial services, and publishers distributing their own editorial content.

Who will pay?

The tax targets only the largest multinational digital groups. Businesses would need to exceed both:

• €1 billion in worldwide group revenues; and
• PLN 25 million in taxable Polish digital service revenues.

The thresholds apply regardless of where the business is established, meaning non-Polish technology companies could fall within scope.

DST Compliance requirements

The tax will be calculated on qualifying revenues generated from Polish users, whose location may be determined using information such as IP addresses, telecommunications data and other commercially available indicators.

Businesses without a Polish establishment may appoint either another group company or a Polish tax representative to manage compliance. Tax representatives must already be VAT registered in Poland and satisfy professional and insurance requirements.

Unlike Polish VAT, the DST operates alongside existing tax obligations. The draft allows reductions for Polish corporate income tax already paid, qualifying R&D expenditure and investment in Polish fixed assets.

Although the proposal is still subject to the legislative process, multinational digital businesses should begin assessing whether their Polish revenues exceed the proposed thresholds and prepare for compliance from 1 January 2027.

January 2026: 3% DST proposal following consultation

Poland’s Ministry of Digitalisation produced a framework for a 3% Digital Services Tax on digital platforms’ advertising, data services and intermediary services. There will now be a public consultation starting in February 2026.

Poland would offer a credit against any DST liability for any Polish corporate income taxes paid.

The Polish DST is modelled after measures in the UK, France, and Spain, targeting large multinational tech companies. A Germany 10% DST proposal is also expected soon.

This reflects the stalled OECD Pillar 1 talks which the new US White House administration pulled out of in February.

The US Digital Services Tax investigation was launched in February, looking at how such levies may indiscriminately target US digital giants. It may seek retaliatory tariffs on countries imposing such DST’s. Recently, U.S. Commerce Secretary Howard Lutnick said Washington would consider such taxes, along with other trade barriers like VAT, when imposing tariffs on the European Union.

DST on digital platforms, advertising and user data

The tax will apply to companies with global revenues exceeding €1 billion and Polish revenues above €250 million, and will focus on three key areas:

1. Digital platforms and applications that enable exchanges of information, goods, or services between users (such as marketplaces, ride-hailing applications, and social media platforms).

2. Targeted digital advertising, especially those relying on user profiling.

3. User data transfer services, including the sale or licensing of data on user activities.

Exemptions from DST net

Several services would be exempt from the DST, including:

• Digital intermediation services primarily providing digital content, communications, or payment services where users do not play a key role in creating value.
• Online sales of goods or services directly through a supplier’s own website, provided the supplier is not acting as an intermediary.
• Services offered by regulated financial institutions.

Polish corporate income tax interaction

To avoid double taxation, the plan includes a mechanism for reducing DST liabilities for companies that already pay corporate income tax (CIT) in Poland.

Tax revenue to be ploughed into local digital development

Revenue collected through the DST is intended to support Polish technology development, innovation, and quality media content. The proposal remains in the consultative stage, with feedback from stakeholders to be incorporated before a draft bill is introduced.

The measure, first announced in March, has already drawn international attention. The U.S. ambassador-designate to Poland at the time warned that the Trump administration could retaliate if Poland moves forward with the DST.

March 2025: 1.5% audio visual media tax to be broadened to DST

Poland’s Finance Minister has indicated that a full Digital Services Tax, similar to those in operation in France and the UK, will be implemented.

See our global Digital Services Tax tracker.

Polish 1.5% foreign streaming video tax

Currently, Poland only has a 1.5% revenue tax on income from foreign streaming services. Companies must generate at least €750 million in global revenue and EUR 5 million in Polish revenue to be subject to these taxes.  Revenues from this levy are funnelled into the Polish media and film sector to promote local-language content creation.

Europe Digital Services Taxes (DST)