The limit for tax payments made by a third party will increase to PLN 5,000
What does this change mean for employers and expat tax settlements in Poland?
Increase of the limit for third-party tax payments (to PLN 5,000) is an important change in the context of Global Mobility and payments made on behalf of employees assigned to Poland (expats). The President has signed the Act of 29 May 2026 amending the Tax Ordinance Act and certain other acts, which introduces, among other changes, an increase of the limit allowing tax payments to be made by a third party (so-called “substitute payer”) to PLN 5,000. The new regulations will enter into force on 1 October 2026.
From this article, you will learn, among other things:
- what the increase of the limit for tax payment by a third party to PLN 5,000 involves,
- what this means for the tax settlements of seconded employees (expats) in Poland,
- what risks and limitations remain despite the change in regulations,
- what actions employers seconding employees to Poland should consider.
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Impact on employers, Global Mobility and expat settlements
The current regulations have long posed practical challenges in Global Mobility, particularly in situations where an employer supports an assigned employee (expat) in settling their tax liabilities on their behalf.
The previously low threshold (PLN 1,000) has resulted in numerous practical difficulties in effectively settling expats’ tax liabilities as a substitute payer. This also applies to cases where the employer acts only as a technical payment intermediary, while the funds actually originate from the employee.
Increasing the limit to PLN 5,000 may partially address these difficulties; however:
- it does not resolve the issue in a systemic manner,
- most expat tax liabilities will still exceed the threshold,
- consequently, the change will not eliminate the challenges related to making tax payments on behalf of foreign employees assigned to Poland,
- increase of the limit indicates that the intent of the legislator is for taxes to be paid solely by taxpayers, which may lead to wider questioning of payments made by a third party acting on the taxpayer’s behalf if the tax amount is higher than PLN 5,000.
What does this mean for employers assigning employees to Poland?
From the perspective of employers assigning employees to Poland:
- the increase of the limit is a positive deregulation signal; however, as a rule, taxpayers should still settle their tax liabilities themselves,
- the impact of this change on Global Mobility processes will remain limited, in particular in standard expat tax scenarios where the amounts due may significantly exceed the threshold,
- higher risk remains for payments exceeding PLN 5,000 (after the change) made by employers on behalf of employees using employees’ funds.
In practice, employers should review their current tax settlement models with regard to payments made on behalf of employees and assess whether existing processes remain compliant with applicable regulations. In particular, it may be advisable to revisit cases where the employer acts as a technical payment intermediary.
Anastazja Naumczyk-Turecka
Maciej Łapuć
