The first half of 2026 brought a number of significant changes regarding the “constitution” of the Polish tax system – the Tax Ordinance.
On 30 April 2026, the Sejm passed the first of three amendments to the Tax Ordinance, which included significant standardisation for the publication of tax rulings issued by local government tax authorities.
Subsequently, on 15 May 2026, the Sejm passed two further amendments to the Tax Ordinance. Their main part was due to come into force on 1 October 2026. The scope of the planned changes was broad and included both deregulatory solutions that were favourable to taxpayers, and regulations raising major doubts – primarily in the area of the statute of limitations for tax liabilities and penal fiscal liability.
Ultimately, the fate of some of the amendments turned out differently.
Amendments providing for:
- The extension of the obligation to publish local government tax rulings in the EUREKA system,
- Simplifications for entrepreneurs, including changes to the reporting of domestic tax schemes,
were signed by the President of the Republic of Poland.
On the other hand, the act encompassing changes to the suspension of the statute of limitations for tax liabilities and penal fiscal liability was vetoed.
What does this mean for entrepreneurs and what changes should they prepare for in the coming months?
Vetoed Tax Changes: Statute of Limitations and Penal Fiscal Code
One of the key proposals provided for the repeal of the controversial Article 70 § 6 point 1 of the Tax Ordinance. This provision concerns the suspension of the statute of limitations for a tax liability in connection with the initiation of penal fiscal proceedings.
In practice, this mechanism has raised doubts among taxpayers and legal representatives for years. The initiation of penal fiscal proceedings could lead to the suspension of the statute of limitations, and thus extend the period during which the taxpayer remained in uncertainty regarding the final settlement of their tax liabilities.
The vetoed act also included a change to the Penal Fiscal Code concerning Article 44 § 2 (specifically, its repeal). Currently, this provision serves a significant protective function, as it links the possibility of conducting penal fiscal proceedings with the expiry of the tax due itself. In other words, in certain cases, the expiry of the tax liability also limits the possibility of further prosecution for a penal fiscal offence related to that liability.
The planned repeal of this provision sparked critical voices from some business circles. It was pointed out that the change could lead to an extension of the period of penal fiscal liability, even when the tax liability itself had already expired. The Ministry of Finance, on the other hand, argued that the proposed solution was systemically coherent and justified from the point of view of the structure of penal fiscal liability.
Why Did the Polish President Veto the Tax Law Amendments?
The President of the Republic of Poland decided to veto the act encompassing changes to the Tax Ordinance and the Penal Fiscal Code. The justification for the decision emphasised the need to protect the legal security of citizens and the predictability of the state’s actions towards taxpayers.
From the perspective of entrepreneurs, this means that the planned changes in this area will not enter into force at this point. At the same time, it should be borne in mind that the legislative procedure may still be continued. The Sejm has the power to override the President’s veto if it obtains a 3/5 majority vote in the presence of at least half of the statutory number of MPs.
What the Presidential Veto Means for Businesses in Poland
The veto – in the context of one of the planned amendments – has a twofold meaning for taxpayers:
- Firstly, the controversial Article 70 § 6 point 1 of the Tax Ordinance, used by tax authorities to instrumentally extend the statute of limitations, remains in force.
- Secondly, the current wording of Article 44 § 2 of the Penal Fiscal Code is preserved. For entrepreneurs, this means maintaining a favourable solution which, in certain situations, limits the possibility of conducting penal fiscal proceedings after the tax liability has expired.
In practice, taxpayers have therefore avoided one of the more controversial changes, but at the same time, there will be no repeal of the provision which has raised objections for years due to the possibility of extending tax proceedings.
New Tax Regulations: Amendments Signed by the President
Regardless of the vetoed act, the President of the Republic of Poland signed two further amendments to the Tax Ordinance.
This is a package of deregulatory and standardising changes aimed at simplifying some of the taxpayers’ obligations, streamlining day-to-day relations with the tax administration and standardising tax knowledge bases.
The End of Domestic MDR Reporting in Poland
One of the most important changes is the abolition of the obligation to report domestic tax schemes, i.e., so-called domestic MDRs (Mandatory Disclosure Rules).
Until now, MDR obligations were a significant organisational burden for many entrepreneurs, advisors, and accountants. They required the analysis of many economic events in terms of a potential reporting obligation, even in situations concerning exclusively domestic transactions.
The amendment aims to limit this obligation. It should be clearly emphasised, however, that the simplification concerns domestic tax schemes. The obligation to report cross-border schemes remains in force.
Simplified Tax Settlements and Facilitations with the Tax Office
The amendment also provides for a number of minor changes aimed at simplifying day-to-day tax settlements.
One of them is raising the limit of the tax amount that can be paid on behalf of another taxpayer – from PLN 1,000 to PLN 5,000. This change may have practical significance, e.g., in corporate groups, family businesses, and in situations where tax settlements are organisationally handled by another entity.
The new regulations are also to concern the rules of accounting for interest and procedures related to the refund of stamp duty and tax overpayments. The aim of these changes is to reduce minor formalities and speed up the handling of simpler tax matters.
EUREKA System: A Centralised Database for Local Tax Rulings
Additionally, the amendment provides for the standardisation of the rules for publishing tax rulings concerning local taxes and charges. Rulings issued by heads of rural municipalities (wójts), mayors, and city presidents are to be made available in a single database maintained by the Director of the National Revenue Information (the so-called EUREKA System).
This solution should make it easier for taxpayers to search for them and compare the positions of individual authorities. Until now, the publication of such rulings was dispersed across the websites of the administrative offices supporting the local government authorities issuing the rulings.
How to Prepare for the Upcoming Tax Changes in Poland?
Entrepreneurs should, first and foremost, verify how the signed amendment will affect their obligations regarding MDR and day-to-day settlements with the tax office.
It is also worth monitoring the further fate of the vetoed act, as a potential overriding of the veto by the Sejm could reopen the path to changes in the scope of the statute of limitations and penal fiscal liability.
At LBKP, we continuously analyse tax changes and their impact on entrepreneurs. Contact us if you want to streamline your tax procedures, verify your MDR obligations, or prepare your company for the new regulations.
