5 September 2025

First Masovian Tax Office – important changes

According to the regulation issued by the Minister of Finance and Economy on August 10, 2025, there will be changes to the list of entities that can access the “super office” services. Starting January 1, 2026, the threshold for qualifying for services from the specialized super tax office will be increased from €50 million to €100 million.

The changes introduced by the Minister of Finance and Economy also include enabling the First Masovian Tax Office to serve entities that are parties to a cooperation agreement concluded with the Head of the National Tax Administration.

Entities that were previously served by the First Masovian Tax Office in Warsaw (i.e., met the current revenue threshold) but do not meet the new threshold (i.e., €100 million) must have the opportunity to elect their current head of the tax office.

To implement the change, taxpayers must submit a relevant declaration to the Head of the First Masovian Tax Office in Warsaw by October 15, 2025. Failure to do so by the deadline will allow them to make such a decision in subsequent tax years (as long as revenues do not fall below €50 million or exceed €100 million).

Additionally, the changes also affect the method of converting euros into Polish złoty. Amounts expressed in euros will be converted into Polish złoty at the average NBP exchange rate from the last business day of the tax year (previously, the regulations referred to the last day of the tax year).

Which entities will the First Masovian Tax Office serve after the changes?

From January 1, 2026, the jurisdiction of the First Masovian Tax Office will include:

• tax capital groups and their constituent companies;
• National Bank of Poland;
• state-owned banks and domestic banks incorporated as companies, and mortgage banks;
• Domestic insurance companies and domestic reinsurance companies;
• public companies with their registered office in the territory of the Republic of Poland;
• taxpayers who are parties to a cooperation agreement;
• legal entities or organizational units without legal personality, excluding taxpayers and payers conducting business activities in the form of a civil partnership, which, as part of their business activities, achieved net revenue from the sale of goods, products, and services exceeding €100 million in the tax year, unless they were classified in other categories in the regulation;
• entities that, as of December 31, 2025, will fall within the jurisdiction of the 1MUS (based on the revenue criterion) and which, in two consecutive tax years (the last one should end in 2024), achieved revenues in the range of €50-100 million in at least one of these years and did not submit a declaration of exclusion from this category by October 15, 2025.

What form and what elements should a declaration of income of €50-100 million contain?

The declaration should be in writing and include:

• taxpayer identification details,
• legal basis,
• date of preparation,
• signature of the authorized person.

The document should be submitted to the Head of the Tax Office. The declaration can be submitted in paper or electronic form.