Poland is poised to implement significant changes to its tax regulations, aiming to improve the relationship between taxpayers and the tax authorities and enhance the efficiency of tax administration. The reforms, currently in draft form, address several key areas, including the statute of limitations for tax liabilities, reporting requirements for tax arrangements, and simplification of tax settlement procedures.
A core element of the proposed changes involves removing a controversial provision that automatically suspended the statute of limitations when criminal fiscal proceedings were initiated. This practice, criticized for allowing tax authorities to extend investigations indefinitely, has faced legal challenges and prompted calls for reform. According to the draft amendment, initiating such proceedings will no longer have this effect, providing greater certainty for taxpayers. This change echoes concerns raised by administrative courts, academics, and taxpayers for years, and follows a signaling decision sent to the Minister of Finance.
The amendments also seek to streamline the reporting of tax arrangements. The Council of Ministers recently passed a bill that includes the abolition of the obligation to report domestic tax arrangements and a reduction in the number and frequency of mandatory disclosure rules (MDR) forms required to be submitted. This simplification is intended to reduce the administrative burden on businesses and focus resources on more complex cross-border tax planning.
Further enhancements are planned for tax settlement processes. These include removing the requirement for taxpayers to apply for a tax overpayment refund when the overpayment arises from a corrected return. The limit for tax payments made by entities other than the taxpayer will be increased from PLN 1,000 to PLN 5,000, and taxpayers will be granted the option to remit tax before the payment deadline. These measures are designed to make tax compliance easier and more efficient.
The changes come after a period of relatively limited activity in corporate taxation during 2024 and early 2025. Prior adjustments focused on implementing existing regulations, such as the minimum income tax and Pillar 2 regulations, and addressing the rollout of the CIT SAF-T file – a standardized reporting format for corporate income tax data. The deadline for mandatory use of the National e-Invoice System (KSeF) has also been postponed to , for entities with gross turnover exceeding PLN 200 million in 2024, and for other VAT-registered businesses.
The planned reforms build on earlier changes to the Tax Ordinance initiated in March 2025. The Ministry of Finance published a new draft amendment on , continuing this process of modernization. The government anticipates that the provisions will become effective on .
The broader context of these changes is a move towards digital tax compliance. Poland is pushing forward with the implementation of KSeF, requiring businesses above a certain turnover threshold to utilize the system for invoicing. This transition, while intended to improve transparency and reduce tax evasion, presents challenges for businesses adapting to the new technology and reporting requirements.
While the specific details of the “deregulation initiative” are still emerging, the overall direction suggests a commitment to reducing the complexity of the Polish tax system and fostering a more collaborative relationship between taxpayers and the authorities. The changes aim to balance the need for effective tax enforcement with the desire to create a more business-friendly environment.
The impact of these changes will be closely watched by businesses operating in Poland. The simplification of reporting requirements and the removal of the statute of limitations suspension are likely to be welcomed by taxpayers, while the continued push for digital compliance will require ongoing investment and adaptation. The effectiveness of the reforms will ultimately depend on their implementation and the extent to which they achieve their stated goals of improving efficiency and fostering trust.
