Draft shield package for companies – tax issues

On behalf of the Kochański & Partners tax advisory team, we would like to update you on the provisional draft “Shield Package for Companies” being developed in connection with the coronavirus pandemic.

Below please find a summary of main assumptions of the proposed changes regarding tax issues, which may be beneficial for entrepreneurs.




  • The right to a one-off settlement of loss of up to PLN 5 million incurred in the current year against 2019 income (by way of a 2019 tax return adjustment) – subject to certain conditions;
  • The right to extend – until June 1, 2020 – the deadline for PIT advances due for March and April 2020 under labour, employment, outworking or cooperative employment relationships, and under cash social insurance benefits paid by tax remitters – subject to certain conditions;
  • Extension of the deadline for notification of payment to an non-“Whitelist” account as long as the state of epidemic threat or the state of epidemic is continuing;
  • The right to deduct certain donations made in 2020 for the purpose of counteracting COVID-19 from the tax base;
  • Exemption of debtors from the obligation to apply bad debt relief provisions – subject to certain conditions;
  • Extension – until July 20, 2020 – of the deadline for payment of the March-May 2020 building revenue tax – subject to certain conditions.



  • Extension – until July 1, 2020 – of the deadline for meeting the obligation to lodge new JPK_V7 files (covering also VAT return data) for large entrepreneurs.


Real estate tax

  • The right of the Municipal Council to introduce a real estate tax exemption for part of 2020 – in certain situations;
  • The right of the Commune Head and City Mayor to extend the deadline for April-June 2020 real estate tax instalments until September 30, 2020 – in certain situations.


Exemption of loan agreements from transfer tax

  • Exemption from transfer tax of loan agreements concluded by August 31, 2020 – subject to certain conditions.


Financial statements

  • The right of the Minister of Finance to issue a regulation allowing for changing deadlines regarding the obligations to prepare, approve and file financial statements.


Suspension of deadlines for proceedings and audits

  • The right to suspend, be it ex officio or upon request, tax proceedings as well as tax and customs tax audits;
  • The right to suspend administrative enforcement proceedings for cash receivables.


Suspension of tax scheme reporting (MDR) deadlines

  • Suspension of deadlines for meeting MDR obligations for non-cross-border schemes from March 31 to June 30, 2020.


NOTE: Most solutions require meeting additional, often unclear conditions.



Agata Dziwisz
Advocate, Partner, Head of Tax Practice
M: +48 668 886 370
E: a.dziwisz@kochanski.pl