Polish businesses face January 31 deadline for revised property tax declarations under new 2025 definitions.
Return to Standard Deadlines
2025 was a transitional period that gave taxpayers time to adapt to the new definitions. In 2026, there is no longer a buffer period – the declaration submitted by January 31 must be substantively correct and reflect all the practice that has developed among authorities in the past year,” emphasizes Wojciech Pławiak, partner at Litigato.
For 2026, the rules known before the reform are back in effect. For companies with an extensive real estate portfolio – especially in logistics, production, trade, and development – this means a significantly shorter window to verify the classification of objects after the 2025 changes. The biggest mistake we see today is the ‘copy-paste’ approach to declarations from previous years. After the 2025 reform, this is a direct path to underpayment or overpayment of tax, and consequently, to a dispute with the municipality,” points out Wojciech Pławiak.
Legacy of the 2025 Reform
As of January 1, 2025, autonomous, tax-specific definitions of building and construction have been in effect, independent of construction law. In practice, in 2025, tax authorities actively shaped new practice by issuing interpretations in which containers placed on concrete blocks were considered buildings or structures if assessed as permanently connected to the ground.
In 2025, we observed an increasingly fiscally aggressive approach by municipalities. Therefore, the 2026 declaration must consider not only the regulations but also the interpretations and the first lines of disputes that emerged in 2025,” adds Pławiak.
Key Risks for Companies
Among the most common risks in 2026 are: too narrow identification of structures (e.g., squares, internal roads, underground networks), incorrect qualification of an object as a building instead of a structure or vice versa, and failure to consider new interpretations regarding permanent connection to the ground and connection to business activity.
In large production plants and logistics parks, the problem may involve thousands of positions in the fixed assets register and extensive technical installations.
What to Do Before January 31
January 2026 is not only the deadline for submitting a declaration, but above all, a time to conclude the effects of the 2025 reform. Companies should, among other things: verify the map of objects (land, buildings, structures) according to new definitions, check the completeness of the records of structures and accompanying infrastructure, and assess the impact of interpretations issued in 2025 on their own properties.
It is important to ensure electronic submission of the declaration with sufficient advance notice. A well-prepared 2026 declaration is today an element of tax risk management. The lack of review after the 2025 reform means that the risk only accumulates,” summarizes Wojciech Pławiak.