⚠ The State Raised Its Own Bank's Tax to Thirty PercentHigh threat

PKO Bank Polski (PKO) — threat to the moat

The corporate income tax on commercial banks went from 19 to 30 percent with four weeks' notice, and PKO's tax bill rose 67,4 percent in the first half of 2026.

On 27 November 2025 the Polish president signed an amendment, in force from 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 framed it as a form of social justice given bank profits during the high-rate period, and as financing unprecedented defence needs; the sector called it discriminatory. It was expected to raise about 6,5 billion złoty in 2026 and more than 20 billion over a decade.

H1 2026 against H1 2025 (%)+19,9%Profit before tax+67,4%Income tax charge+3,1%Net profit8 319m zł earned before tax, 3 029m zł paid, 5 290m zł kept
The whole threat in one picture. PKO did everything right, grew pre-tax profit a fifth, and kept almost none of it.

PKO's first half of 2026 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 bank earned a fifth more and kept a thirtieth more.

What makes this a root-level threat rather than a tax footnote is who did it. The State Treasury holds 367 918 980 shares, 29,43% of PKO3 — so the largest shareholder bore 29,43% of the cost as an owner and collected 100% of it as a government. There is no board, no strategy and no operational excellence that alters that arithmetic, and PKO's competitors were affected identically, so there is not even relative disadvantage to complain about.

The mitigations are real. The asset-based bank levy falls from 0,0366% to 0,0329% in 2027 and 0,0293% in 20284, and the corporate rate is legislated to step down twice. The bank still earned a 19,5% return on equity in 20255 and paid out 75% of profit6.

The number that tests this threat is the effective tax rate in the 2027 accounts. If it falls to 26% as written, 2026 was a peak and the earnings recover mechanically. If the step is deferred, or a further levy is added — a Polish finance minister proposed exactly that in July 2026 — then a 19,5% pre-tax return on equity is a number shareholders will keep progressively less of, and the multiple should reflect a permanent claim rather than a temporary one.

The number that tests this threat
Reported
Income tax charge against pre-tax profit
3 029m zł, up 67,4%, while pre-tax profit rose 19,9%

This is the whole threat in one comparison. In the first half of 2026 PKO earned 8 319m złoty before tax, 19,9% more than a year earlier - and paid 3 029m in tax, 67,4% more. Net profit rose 3,1%. The bank did everything right and kept almost none of it. The rate falls to 26% in 2027 and 23% in 2028, so the number to watch is whether that timetable survives the next budget.

Source: PKO Bank Polski S.A. Group Directors' Report for H1 2026 ↗
References
  1. ReportedOn 27 November 2025 the Polish president signed an amendment, in force from 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 ↗
  2. ReportedNet profit 5 290 million — up 3,1%.
    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 ↗
  3. ReportedThe State Treasury holds 367 918 980 shares, 29,43% of PKO — so the largest shareholder bore 29,43% of the cost as an owner and collected 100% 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 ↗
  4. ReportedThe asset-based bank levy falls from 0,0366% to 0,0329% in 2027 and 0,0293% in 2028, and the corporate rate is legislated to step down twice.
    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 ↗
  5. ReportedThe bank still earned a 19,5% return on equity in 2025 and paid out 75% of profit.
    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 ↗
  6. ReportedThe bank still earned a 19,5% return on equity in 2025 and paid out 75% of profit.
    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 ↗
Sources
Generated September 24, 2026