The Ministry of Finance is working on amendments to the Tax Code. The new regulations are expected to facilitate taxpayers’ interaction with the system and tax authorities while optimizing administrative burdens. The amendments include changes to the statute of limitations, a reduction in reporting obligations for tax schemes (MDR), and lower penalties for formal violations. The new provisions are planned to come into force in 2026.
Information on tax schemes (MDR)
Regarding tax scheme reporting (MDR), starting in 2026, lawyers, attorneys, tax advisors, and patent attorneys will be exempt from the obligation to report MDR. However, they will still be required to inform their clients—”users” or “promoters”—about their obligation to submit such information to the National Tax Administration.
The Minister of Finance will have the authority to issue regulations allowing certain transactions to be exempt from MDR reporting requirements, and MDR-2 reporting will be abolished.
Additionally, MDR-3 information will only need to be submitted once per year, and documents may be signed by representatives.
Reduction of fines
Fines for late submission of tax scheme information or failure to provide it will be reduced from 720 to 240 daily rates.
The new version of the Tax Code also provides for the elimination of sanctions:
- For the lack of tax scheme data by an obligated entity or for providing the information late.
- In situations where no separate request was made to the client for a written statement that the agreement is not a tax scheme or for submitting such a request after the deadline.
To improve the efficiency of tax authorities, it is proposed to exempt the Head of the National Tax Administration (Szef KAS) from the obligation to assign a new Tax Scheme Number (NSP) if such information has already been submitted.
The Minister of Finance will have the right to submit requests to the Supreme Administrative Court for the issuance of an abstract ruling, which, in turn, will enable more consistent application of tax regulations.
“Regarding the issue of eliminating the basis for suspending the statute of limitations on tax obligations due to the initiation of proceedings for a tax crime or offense, we would like to emphasize that we are currently working on replacing this basis with another legislative solution,“—as reported by the Ministry of Finance.—”These efforts aim to ensure that the future regulation not only meets external demands but also enables the effective fulfillment of the tasks assigned to the National Tax Administration.“
