⚠ A Fixed Charge Meets a Falling MarginHigh threat

PKO Bank Polski (PKO) — threat to the moat

An asset-based levy takes a larger share of profit every year the margin narrows.

The tax on certain financial institutions took 1 349 million złoty in 20251 and is charged on assets regardless of profitability.

Bank levy rate, by statute0,0366%20250,0366%20260,0329%20270,0293%2028The levy falls only because the income tax rate rose to more than replace it
The rate comes down and the total burden goes up. Trading a charge on assets for eleven points of income tax is not relief.

That is tolerable while the interest margin is 4,76%2 and becomes uncomfortable as it falls — and it has already fallen to 4,47%3. The levy scales with the balance sheet, which grew 11,0% in 20254 and is still growing 13,9%5, so the charge rises as the income supporting it thins.

The scheduled rate reductions help: 0,0366% to 0,0329% in 2027 and 0,0293% in 20286. But they are part of the same package that raised corporate income tax to 30%, so the sector is not being relieved — it is being taxed differently.

The perverse consequence is worth naming. A bank facing a fixed asset charge and a falling margin has a rational incentive to lend less, at exactly the point in the cycle when policy wants it to lend more.

The direction of travel is already visible in the arithmetic. The levy took 1 349 million złoty in 20257 against a 4,76% interest margin; the same charge against the 4,47% margin PKO reported for the first half of 20268 is a larger claim on a smaller spread, and nothing about the calculation changed.

The measure is the levy as a share of pre-tax profit. It is roughly an eighth today; a rate cycle that halves the margin without a corresponding cut in the levy would make it materially more than that.

References
  1. ReportedThe tax on certain financial institutions took 1 349 million złoty in 2025 and is charged on assets regardless of profitability.
    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 ↗
  2. ReportedThat is tolerable while the interest margin is 4,76% and becomes uncomfortable as it falls — and it has already fallen to 4,47%.
    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. ReportedThat is tolerable while the interest margin is 4,76% and becomes uncomfortable as it falls — and it has already fallen to 4,47%.
    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 ↗
  4. ReportedThe levy scales with the balance sheet, which grew 11,0% in 2025 and is still growing 13,9%, so the charge rises as the income supporting it thins.
    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 ↗
  5. ReportedThe levy scales with the balance sheet, which grew 11,0% in 2025 and is still growing 13,9%, so the charge rises as the income supporting it thins.
    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 ↗
  6. ReportedThe scheduled rate reductions help: 0,0366% to 0,0329% in 2027 and 0,0293% 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 ↗
  7. ReportedThe levy took 1 349 million złoty in 2025 against a 4,76% interest margin; the same charge against the 4,47% margin PKO reported for the first half of 2026 is a larger claim on a smaller spread, and nothing about the calculation changed.
    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 ↗
  8. ReportedThe levy took 1 349 million złoty in 2025 against a 4,76% interest margin; the same charge against the 4,47% margin PKO reported for the first half of 2026 is a larger claim on a smaller spread, and nothing about the calculation changed.
    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 ↗
Sources
Generated September 24, 2026