Poland proposes shorter tax checks and longer appeal deadlines

Existing checks and proposed safeguards

The affected statute is the Act of 29 August 1997 — Ordynacja podatkowa, Poland’s Tax Code. The Sejm’s 8 October 2026 compilation already gives authorities verification powers under Articles 272–274c: checking returns, payments, registration documents and specified corporate-tax information, requesting explanations and examining business counterparties’ records.^[2]

UD483 would broaden checks and evidence while requiring start, completion and outcome notices. It envisages protection against subsequent late-payment interest and fiscal-criminal liability where checks found no irregularities or taxpayers followed the findings. These are policy assumptions, not enacted protections.^[1]

Keep different challenge routes separate

Article 223(2) currently provides 14 days from service for an appeal; UD483 proposes 30 days and an option to waive appeal rights. Separately, Article 274(3) permits a 14-day objection cancelling an authority’s correction of obvious return errors. The announced appeal extension should not be applied to that distinct objection route.^[1][2]

Other proposals cover wider voluntary-security forms, reduced late-interest treatment for late original returns, priority use of information authorities already hold or can obtain, merits review of expired security decisions, and tax-clearance certificates following restructuring arrangements. A small-liability rule would restrict state-tax proceedings, with a separate municipal option.^[1]

Present conditions still matter

The existing Article 33d lists voluntary-security forms, including bank guarantees and deposits. Article 56a’s reduced-interest route concerns qualifying corrections within six months, payment within seven days and specified exclusions. Article 306e already addresses deferred or instalment-paid arrears for certificate purposes. These provisions do not establish that UD483’s broader proposals are already available.^[2]

For multinational groups, this is a proposed procedural package, not authority to change live dispute deadlines. Cabinet adoption is targeted for the first quarter of 2027, not a verified commencement date. Operative wording and transition rules remain to be settled.^[1][2]