Abstract

The article demonstrates how the global minimum tax (GloBE) reshapes the economic effectiveness of Polish CIT reliefs and exemptions, and consequently - Poland’s perceived tax attractiveness. The introduction opens with a concise overview of GloBE’s origins as a policy response to the “race to the bottom”, base erosion (BEPS), and fiscal imbalances across jurisdictions. The analysis shows that key incentives - particularly zone-based exemptions (PSI/SSE), as well as the R&D tax allowance - may lose real economic impact when they drive the jurisdictional ETR below 15%, triggering top-up tax liability. Currently available GloBE mitigating mechanisms (SBIE and jurisdictional blending) operate only in a targeted, case-by-case manner and do not provide systemic protection of investment incentives. The announced by OECD SBTI Safe Harbour will apply to fiscal years beginning after 1 January 2026, and additionally, the QTI mechanism is subject to a requirement for strictly defined limitations. The absence of final domestic shielding solutions increases the risk of eroding Poland’s competitive position and investment outflows.