⚠ The Rules Can Be Changed by the Largest ShareholderHigh threat
PKO Bank Polski (PKO) — threat to the moat
In November 2025 the owner raised its own bank's tax rate by eleven points and gave four weeks' notice.
The protection described on this page and the threat are the same institution.
On 27 November 2025 the president signed an amendment, in force 1 January 2026, raising corporate income tax on commercial banks from 19% to 30%, scheduled to fall to 26% in 2027 and 23% in 20281. The finance ministry described it as a form of social justice given bank profits during the high-rate period; the sector called it discriminatory. It was expected to raise about 6,5 billion złoty in 2026 alone.
PKO's first half shows what an eleven-point rate rise does to a bank having an excellent year: profit before tax 8 319 million złoty against 6 939 million, up 19,9%; income tax 3 029 million against 1 809 million, up 67,4%; net profit 5 290 million, up 3,1%2.
The State Treasury holds 29,43%3 and therefore bore 29,43% of that cost as a shareholder while collecting all of it as a government.
The scheduled reductions to 26% and 23% are the mitigation, and they are legislation rather than contract.
The number that tests this threat is the effective tax rate. If the step down to 26% arrives in 2027 as written, this was a temporary levy. If it is deferred or the rate rises again, then the return on equity of 19,5%4 is a pre-tax achievement that shareholders will see progressively less of.
- ReportedOn 27 November 2025 the president signed an amendment, in force 1 January 2026, raising corporate income tax on commercial banks from 19% to 30%, scheduled to fall to 26% in 2027 and 23% in 2028.Polish corporate income tax on banks - the amendment signed by the president on 27 November 2025 and in force from 1 January 2026, raising the rate on commercial banks from 19% to 30% for 2026, then 26% in 2027 and 23% in 2028, with the asset-based bank levy falling from 0,0366% to 0,0329% and 0,0293%; framed by the finance ministry as social justice and as financing defence needs, criticised by the sector as discriminatory, and estimated to raise about 6,5bn złoty in 2026 — 2026-2028 · publ. November 2025 · source ↗
- ReportedPKO's first half shows what an eleven-point rate rise does to a bank having an excellent year: profit before tax 8 319 million złoty against 6 939 million, up 19,9%; income tax 3 029 million against 1 809 million, up 67,4%; net profit...PKO Bank Polski S.A. Group Directors' Report for the six months ended 30 June 2026, published with reviewed financial statements (profit before tax of 8 319m złoty up 19,9%, income tax of 3 029m up 67,4%, net profit of 5 290m up 3,1%, return on equity of 19,3%, cost-to-income of 31,4%, interest margin of 4,47% against 4,91%, cost of risk of 0,29%, total assets past 608 448m, 12,6 million customers, common equity tier 1 of 15,55%, and a further 685m złoty of convertible-currency legal risk) — H1 2026 · publ. 13 August 2026 · source ↗
- ReportedThe State Treasury holds 29,43% and therefore bore 29,43% of that cost as a shareholder while collecting all of it as a government.PKO Bank Polski S.A. Group Directors' Report for 2025 - capital, shareholders and levies (the State Treasury holding 367 918 980 shares or 29,43% of the capital and votes, Nationale Nederlanden at 7,32% and Allianz Polska at 6,01%, own funds of 50 122m złoty, a total capital ratio of 17,10%, the 75% dividend payout from the 2025 profit, and the 1 349m złoty tax on certain financial institutions) — FY2025 · publ. 12 March 2026 · source ↗
- ReportedIf it is deferred or the rate rises again, then the return on equity of 19,5% is a pre-tax achievement that shareholders will see progressively less of.PKO Bank Polski S.A. Group Directors' Report for 2025 - the efficiency and quality ratios (return on equity of 19,5%, return on assets of 1,9%, a cost-to-income ratio of 31,1%, net interest margin of 4,76%, cost of credit risk of 0,30% and impaired exposures at 3,34% of the portfolio) — FY2025 · publ. 12 March 2026 · source ↗