Keep calm and let us manage your taxes

On 19 August, during a press conference, the Prime Minister announced a package of tax changes planned for next year. According to the announcement, the reform is intended, on the one hand, to ease the burden on the middle class and, on the other, to shift a greater fiscal burden onto the wealthiest individuals and the largest companies. We take a look at the proposals included in the announced package and explain what they might mean for taxpayers.

Family foundations were intended to provide entrepreneurs with a stable framework for intergenerational wealth management. Yet not even four years have passed since the first such foundations were established, and the rules governing their taxation are set to be changed once again. This is because the scale of interest and the practical problems uncovered have overwhelmed the drafters of the legislation, as best illustrated by the figures – 927 applications for individual tax rulings and 77 opinions issued from the Head of the National Revenue Administration. This does not, however, mean that family foundations are being used on a massive scale for aggressive tax optimisation. A significant proportion of the queries concerned simply how to correctly apply the complex regulations.

Three years. That’s how long we’ve been waiting for what the Council of Ministers had seen in the data from the outset – and has now disclosed in its review of the Family Foundation Act. The document not only diagnoses the problems, but also previews substantial changes to rules that founders and their advisers treated as settled and stable. And therein lies a problem that goes far beyond tax matters. If the rules of the game are changed while the game is being played, there can be neither planning stability nor trust in the law. It is no coincidence that one of the greatest concerns among entrepreneurs considering setting up a foundation is not the level of taxation, but the stability of the legal framework – which today is once again being called into question.

The past year has brought a series of enforcement actions that clearly signal a tightening approach by the Polish customs and revenue authorities towards breaches of the sanctions regime. Importantly, businesses should already be preparing for further changes, as the European Union has announced its 21st sanctions package and updated the list of designated persons and entities. We examine the key developments and offer guidance on how to minimise the risk of non-compliance.

The bill amending the General Tax Code (No. UC138) fundamentally overhauls the rules governing the tax liability of third parties for capital companies’ tax arrears.  It comes in response to recent CJEU judgments, the Ombudsman’s February statement and the post-audit report of the Supreme Chamber of Audit (NIK) of December 2025. We examine what’s changing, who will be affected by the new rules and what steps are worth taking right now.

A draft bill amending the General Tax Code (No. UDER110) has been submitted for consideration by the Council of Ministers. The bill introduces the tax settlement agreement, a new form of amicable dispute resolution between taxpayers and the tax authority. The draft is open for inter-ministerial review and public consultation until 19 June, with the proposed date of entry into force being 1 January 2028. Below, we examine who may apply for a settlement agreement, when, and on what terms, and how the process may work in practice.

Just a few years ago, SENT (the Electronic Transport Monitoring System) was almost exclusively associated with tanker trucks and the fuel market. This is now a thing of the past. Today, it is an inspection tool that is increasingly being used for shipments of fruit, and, as of mid-March, even containers of clothing and footwear.

The deposit-return system has been in place since October 2025, raising significant tax concerns from the outset. Although the regulations came into force, it was unclear for a long time how to apply them in practice. Some of the regulations needed clarification, some solutions were missing and the published explanations did not cover all the key issues. Consequently, the market began to develop its own operating standards.

A new draft law proposing changes to the way the National Labour Inspectorate operates has been submitted to the Sejm. During its first reading on 25 February, the draft was not rejected and was therefore referred to the Social Policy and Family Committee for further consideration. Despite the concerns and controversies raised so far, including by businesses, the legislature continues to pursue the thorough modernisation of Poland’s employment model, which involves increased supervision of the labour market and curbing the abuse of civil law contracts. In this article, we will take a look at the proposals included in the new draft and explain what they mean for businesses.

The most important changes brought about by the amendment to the Act on the National Revenue Administration are that uncertainties will be resolved in favour of the taxpayer, and that taxpayers will have the opportunity to respond during a customs and tax audit.

The introduction of the National e-Invoice System (KSeF) represents one of the most significant challenges for group companies in recent years. Although the KSeF is intended to simplify the invoicing process and reduce tax abuse, it also has a significant impact on transfer pricing, particularly with regard to the documentation and settlement of TP adjustments.

From 1 January 2026, new limits will come into force regarding the inclusion of depreciation charges and lease payments for passenger cars in tax-deductible costs.

On 4 August 2025, the Ministry of Finance presented a draft amendment to the General Tax Code which could be one of the most significant reforms in recent years. The most crucial aspect of the proposed changes is the elimination of the mechanism that suspends the statute of limitations for tax liabilities when criminal tax proceedings have been initiated.

On 3 July 2025, the Ministry of Finance published draft tax explanations regarding VAT within the new deposit-return system. The system is intended to promote the recycling and reuse of beverage containers, such as glass and plastic bottles and cans.

This principle, which states that doubts should be resolved in favour of the taxpayer, is set out in Article 2a of the General Tax Code and applies only in cases involving vague regulations. In practice, this leaves the tax authorities with considerable leeway for arbitrary application in proceedings where factual findings are crucial.

The significant changes in the tax environment and the growing expectations for fiscal transparency have prompted the legislature to streamline the existing provisions on the system for reporting tax schemes (MDR), thereby eliminating some procedural ambiguities. According to ministerial announcements, the main aim of the amendments is to improve the readability, clarity and consistency of the reporting system and more closely align it with that in force in the wider EU.

Landmark judgment of the CJEU of 27 February 2025 in case C-277/24 (Adjak) on the liability of management board members for a company’s tax debts 

The Polish tax system could be in for a revolution. The Ministry of Finance has announced draft changes aimed at simplifying, streamlining and, in some areas, tightening the rules for dealing with the tax authorities.

Over the past few months, we have attended meetings with the Ministry of Finance regarding planned changes to the tax system. Thanks to this, we know exactly what is on the horizon and how it will affect the daily lives of taxpayers.

On the occasion of another anniversary of Russia’s attack on Ukraine, the Polish legislature decided to tighten regulations on economic cooperation with Russia and its allies.

The year 2025 brings significant changes to tax legislation that will affect businesses, individuals and corporations. We look at what you should know and how to properly prepare for the new requirements.

November saw the issue of two important general rulings on withholding tax. The first concerns certain conditions for dividend exemptions and the second, conditions for interest and royalties. In addition, some notable tax clarifications are expected to appear by the end of the year. We take a closer look at the Ministry's general rulings and their possible implications.

The Polish banking sector is currently facing another major challenge related to Swiss franc issues. This time, however, it concerns the tax consequences of settling loans taken out in CHF.

As we approach the fourth anniversary of the introduction of this levy, it is a good time to take stock of its impact and the doubts surrounding its application. Today, we can see that the revenue from the levy bears no relation to the ever-decreasing sales volumes. This points to a systemic problem.

Tax governance is becoming a key element of the ESG strategy.

We take a look at current trends and how AI is being implemented in the field of tax auditing.

In an era of ubiquitous tax compliance inspections, the implementation of an appropriate oversight framework appears to be critical to the safe operation of a business.

In the new bill, the Ministry has proposed a new definition of a structure.

The Minister of Finance has announced a plan to reduce the Belka tax, to come into effect on 1 January 2025. And although he has said that the groundwork is already being laid, he has not yet revealed all the details of the proposed changes.

Plans to introduce the National eInvoicing System (KSeF) have been suspended for at least two years.

Individuals with an income of more than PLN 1 million have until 30 April to pay the 4% solidarity levy. It is worth checking now whether and how losses from previous years have been settled so far.

The impending Bitcoin halving, the Ministry of Finance’s announcement of new regulations for crypto-assets, and the PIT settlement for virtual currency trading are just some of the changes that cryptocurrency enthusiasts can expect to see in the coming weeks.

Trading in cryptocurrencies not falling within the scope of activities of family foundations.

How to avoid joint and several liability for a company’s tax debts?

By when do sole proprietors and non-corporate entities have to choose their form of taxation? Which is the most advantageous? This article analyses and explains the available options.

The implementation deadline of 1 July 2024 for the National e-Invoicing System (KSeF) has been suspended, announced the Minister of Finance.

Recently, banks have questioned the tax treatment of reimbursements to CHF mortgage borrowers in the event that a CHF mortgage agreement is declared invalid by a final and non-appealable judgement.

We look at whether the KSeF will be a help or a hindrance for businesses, looking at both the pros and cons of the new system.

According to the Supreme Administrative Court (Naczelny Sąd Administracyjny, NSA), a taxable person may not be deprived of the right to deduct VAT simply because a legal transaction is invalid from a civil law perspective.

Management board members who also provide services to companies need to exercise caution, as the tax authorities have changed their previous positive attitude and are increasingly refusing to issue tax rulings for this type of arrangement.

If you are considering using a particular relief, it is worth doing a thorough analysis of the tax legislation and checking whether you are actually entitled to it.

This year, the Ministry of Finance has decided not to extend the deadlines for fulfilling transfer pricing obligations. This means that the deadlines resulting directly from income tax acts will apply.

The landmark judgment of the Constitutional Tribunal is the beginning of the road to the introduction of a new definition, which will finally resolve the dispute that has lasted for over a decade.

Solidarity levy: a legislative oversight is good news for taxpayers

The deadlines for meeting transfer pricing obligations for 2022 are approaching.

On 15 March this year, the Standing Committee of the Council of Ministers gave its favourable opinion on a bill concerning amendments to the VAT Act and certain other acts in connection with the introduction of a mandatory National e-Invoicing System (KSeF).

On 8 March this year, the first reading was held of the bill amending the Value Added Tax Act and certain other acts – i.e. the so-called SLIM VAT 3 (print no. 3025).

Withholding tax (“WHT”) is applicable to taxable persons paying both PIT and CIT, and applies to monies paid to foreign entities.

With the beginning of 2023, let’s take a brief look at the major tax solutions that came into effect from 1st January.

The exemption from dividend withholding tax provided for in Article 22(4) of the CIT Act has repeatedly aroused controversy among taxpayers due to its inconsistent interpretation by tax authorities and administrative courts.

When trying to determine the VAT consequences of NFT disposal, the first question to be answered is what type of an NFT are we dealing with?

Arrangements and consultations on the draft act amending the VAT Act and certain other acts, i.e. the so called SLIM VAT 3 (draft No. UC128), were scheduled to complete by 26 August. It is assumed that the draft act will enter into force on 1 January 2023, with one exception being changes to VAT sanctions, […]

On 28 June 2022, a draft of further amendments to the Personal Income Tax Act and other acts – Polish Deal 3.0 – was published on the Government Legislation Centre website (draft No. UD404).

On 28 June 2022, a draft of further amendments to the Personal Income Tax Act and other acts – Polish Deal 3.0 – was published via the Government Legislation Centre website (draft No. UD404).

Under the CIT Act, taxpayers are normally required to file the TPR form and a statement on the preparation of the local file for 2021, by the end of the ninth month after the end of the financial year.

On 12 May 2022, the lower house of the Parliament (Sejm) adopted the Amendment to the Personal Income Tax Act and Certain Other Acts - the so-called Polish Deal 2.0 (print no. 2186). Below we present a summary of what we believe to be the most important tax solutions.

Natural gas as a 'transition fuel' for Europe on its path towards a zero-carbon economy was supposed to help gradually reduce greenhouse gas emissions. However, this environmentally-sound objective now needs a second look, particularly when gas market developments may affect the viability of new gas-fired generation projects, and when permanent impediments to gas availability may even prevent their uninterrupted and efficient operation.

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