## [Poland: Current status and key proposals of Tax Deregulation 2.0](/en_GB/new/poland-current-status-and-key-proposals-tax-deregulation-20) # Poland: Current status and key proposals of Tax Deregulation 2.0 Poland - 08 / 21 / 2026 Maciej Nowicki and Angela Kopczyk - - [](https://www.linkedin.com/sharing/share-offsite/?url=https://www.garrigues.com/en_GB/new/poland-current-status-and-key-proposals-tax-deregulation-20) - []() - []() Previous Next **The Polish government has presented a package of proposals entitled “Deregulation 2.0” concerning tax administration and tax law. Their stated aim is to simplify tax settlement and increase legal certainty by improving relations between the tax administration, taxpayers and entrepreneurs. Three areas have so far been included as separate projects in the Council of Ministers’ work schedule, but the draft legislation has not yet been published. These measures have only been announced so far, and their scope and timetable may change.** The package is the next stage of the government’s deregulation programme in Poland. “Deregulation 2.0” is not currently a single draft law. On 6 July, a dozen or so proposals were presented. Three areas covered by them have so far been given separate entries in the Council of Ministers’ schedule of legislative and policy work: - the first (UD436) concerns the introduction into the Tax Ordinance (*Ordynacja podatkowa*) of framework rules for the tacit resolution of matters (*milczące załatwienie sprawy*); - the second ([UD445](https://www.gov.pl/web/premier/projekt-ustawy-o-zmianie-ustawy--ordynacja-podatkowa-oraz-niektorych-innych-ustaw8)) covers reform of tax rulings (*interpretacja podatkowa*) and opinions on the application of WHT preferences (*opinia o stosowaniu preferencji WHT*); - the third ([UD450](https://www.gov.pl/web/premier/projekt-ustawy-o-zmianie-ustawy--ordynacja-podatkowa7)) concerns centralising the issuance of individual tax rulings (*interpretacja indywidualna*) on taxes and charges administered by municipal tax authorities, by transferring this power to the Director of National Revenue Information (*Dyrektor Krajowej Informacji Skarbowej*). Each of the three project cards envisages adoption of the draft by the Council of Ministers in Q4 2026. Only the UD450 card specifies a planned date for the legislation to enter into force: 1 July 2027. At the time of publication of this article, apart from brief information on the reasons for and need for the measures, no draft texts, explanatory memoranda or regulatory impact assessments had been published. The discussion of the selected measures below is therefore based on the [Ministry of Finance announcement of 6 July 2026](https://www.gov.pl/web/finanse/deregulacja-20-przyjazna-administracja-skarbowa-i-pewnosc-prawa-podatkowego) and the cards available in the legislative work schedule that describe the objectives of those projects. **Digitalisation of VAT settlements** One of the key elements of the package is further digitalisation of VAT settlements. A free application is expected to be made available, enabling e-receipts to be issued on mobile devices. It is intended to be a voluntary alternative to physical and virtual online cash registers. Customers could receive either a receipt bearing a QR code or an e-receipt. The data collected in the system would then be used to prepare pre-filled VAT returns. According to a government estimate, the pre-filled return service could cover approximately 2 million taxpayers who file VAT returns. Filing the prepared return would remain voluntary and require verification by the taxpayer. The actual benefits can be assessed only once the draft provisions and technical framework have been presented. Key issues will include, in particular, the scope of the data used by the administration, responsibility for verifying those data, and the relationship between the new solution and the National e-Invoicing System (*Krajowy System e-Faktur*, KSeF), the Standard Audit File for Tax (*Jednolity Plik Kontrolny*, JPK) and existing online cash registers. **Tax rulings and WHT opinions: validity, extension and centralisation** Current legislation does not set a predetermined validity period for an individual tax ruling. Project UD445 envisages introducing a five-year validity period for individual tax rulings, while the validity of opinions on the application of WHT preferences would be extended from 36 months to five years. Validity would not be extended automatically. Before the five-year period expired, the applicant would have to apply for an extension. In the case of an individual tax ruling, the application would be free of charge and the extension would concern future events. If the authority did not decide on the application before the ruling or WHT opinion expired, the ruling or opinion would remain valid for a further five years. The project also provides for transitional provisions: - Rulings issued before 1 January 2023 would expire on 30 June 2028. - Rulings issued between 1 January 2023 and 31 December 2027 would expire five years after issue, but no earlier than 1 January 2029. The project would, however, provide for a procedure for extending the validity period. At the same time, the project is intended to strengthen the protective function of general tax rulings (*interpretacja ogólna*) by providing that taxpayers who have relied on a ruling in force would not suffer adverse consequences if the tax authorities subsequently changed their position. A change to the provisions addressed by an individual tax ruling would cause it to expire by operation of law. A change to the provisions of a double taxation treaty would have the same effect on a WHT opinion. The planned five-year period would, however, be only the maximum validity period for the opinion. It is worth noting that, under the [current CIT provisions](https://eli.gov.pl/eli/DU/2026/554/ogl), a material change in the factual circumstances or cessation of the conditions for applying the preference may result in earlier expiry. The centralisation of the issuance of rulings on local taxes and charges has been included in the Council of Ministers’ work schedule as a separate project, [UD450](https://www.gov.pl/web/premier/projekt-ustawy-o-zmianie-ustawy--ordynacja-podatkowa7). According to its project card, the power to issue these rulings would be transferred to the Director of National Revenue Information. The competent municipal tax authority would receive a draft ruling and have 14 days to issue an opinion. If it did not issue an opinion, this would be treated as approval. In cases specified by statute, the municipal authority could appeal (*skarga*) the ruling before a regional administrative court *(wojewódzki sąd administracyjny)*. From the taxpayer’s perspective, the most significant proposal is the announced suspension of the protection under [Articles 14k–14m of the Tax Ordinance](https://eli.gov.pl/eli/DU/2026/622/ogl). If the municipal tax authority brought a judicial challenge, the protection under Articles 14k–14m would not apply while the court proceedings were pending. According to the UD450 project card, it would take effect only once the challenge had been finally dismissed or rejected. The government has also announced that the system of binding tax information instruments – currently including, among other things, binding VAT rate information (*wiążąca informacja stawkowa*) and binding excise information (*wiążąca informacja akcyzowa*) – would be extended to income taxes (PIT and CIT), and that these instruments would be brought under a single procedure. **Tacit resolution of matters and verification activities** According to the UD436 project card, plans call for the creation of a general framework for the tacit resolution of matters under the Tax Ordinance. The mechanism would be available only where a specific provision expressly provided that the authority’s failure to act was to have that effect. The Ministry of Finance announcement lists examples of matters that could be covered by this mechanism, including restoration of a time limit (*przywrócenie terminu*), extension of an accepted security arrangement, suspension or resumption of proceedings, and withdrawal of an administrative appeal (*odwołanie*). Separate proposals concern tax verification activities. The taxpayer would receive clear notice of their commencement and completion, while the authority would request only documents that it could not obtain from the available systems. Protection has also been announced for taxpayers who act in accordance with findings made during tax verification activities. Its exact scope, including its effects on interest and fiscal-criminal liability (*odpowiedzialność karnoskarbowa*), can be assessed only once the draft law is available. **Appeals, security, corrections and the "materiality principle"** Further proposals include extending the deadline for lodging an administrative appeal against a tax decision from 14 to 30 days. The government has also announced a mechanism allowing a decision favourable to the taxpayer to be given effect more quickly once the taxpayer has waived the right to appeal. It is also planned to expand the range of forms of security available at the taxpayer’s choice to include a compulsory mortgage (*hipoteka przymusowa*) and pledges over equity interests (*udziały*), shares (*akcje*) and movable property, and to strengthen the review of security decisions (*decyzje zabezpieczające*). This therefore does not involve creating these legal mechanisms from scratch but changing the rules governing their use as alternatives to more burdensome forms of security. The “materiality principle” is intended to limit the commencement of proceedings concerning trivial transactions of minimal fiscal significance, except where there is deliberate action to the detriment of the State Treasury (*Skarb Państwa*). This measure is separate from the preferential treatment announced in connection with a voluntary correction. The [Tax Ordinance](https://eli.gov.pl/eli/DU/2026/622/ogl) already provides, subject to the statutory conditions, for a late-payment interest rate reduced to 50% following an effective correction, while the [Fiscal Penal Code](https://eli.gov.pl/eli/DU/2025/633/ogl) (*Kodeks karny skarbowy*) provides for conditional non-liability to punishment (*warunkowe niepodleganie karze*) once a return has been corrected and the amount due has been paid. According to the Ministry announcement, the interest rate reduced to 50% and protection against fiscal-criminal liability would apply to a correction made after an automated system alert but before the tax office reacted. The reduced interest rate would also apply where a taxpayer voluntarily filed an initial return late and paid the tax without first being called upon to do so. The final scope of these preferences will depend on the future provisions. **Significance for entrepreneurs** In line with their stated objectives, the measures discussed are intended to provide greater predictability and protection for taxpayers in their dealings with the tax administration. For entrepreneurs, the introduction of the announced changes may primarily reduce the financial and procedural risks associated with day-to-day dealings with the tax authorities. Existing arrangements, which in practice have often created uncertainty for taxpayers, are intended to be eased or supplemented by additional safeguards. All these plans currently remain no more than announcements, and experience from the first stage of deregulation – during which some intended changes did not enter into force because the President vetoed the Act – shows that the legislative process in this area may be lengthy and does not guarantee that the proposed measures will ultimately be adopted. The extent of the eventual change in the legal framework will depend on the final wording of the provisions and how the tax authorities apply them in practice. 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