MGI Modzelewskisp. z o.o. + limited partnership

Reform of Poland’s tax ruling system: five-year validity and centralisation of municipal tax rulings

When does a supply of goods take place for VAT purposes? The case concerned a company making domestic and cross-border supplies of goods through third-party carriers. Domestic transport took between two and seven days, while international deliveries could take up to several weeks. The transactions were carried out under the Incoterms DAP rule. According to the facts presented by the […]

Reform of Poland’s tax ruling system: five-year validity and centralisation of municipal tax rulings

Why are tax rulings to be valid for only five years? The Polish Tax Ordinance currently does not impose a general expiry date on individual tax rulings. This does not mean, however, that a ruling, once obtained, will protect the taxpayer indefinitely. A ruling provides protection only if the transaction or arrangement carried out in practice corresponds to the facts or future event described […]

B2B arrangements under tax scrutiny: how Poland’s UD116 bill could change the tax treatment of entrepreneurs

The proposed tax changes form part of a broader regulatory focus in Poland on how B2B contracts are used in practice. Since 8 July 2026, new rules have also been in force strengthening the powers of the Polish National Labour Inspectorate in relation to civil-law contracts and B2B arrangements that, in practice, replace an employment relationship. The labour inspection reform and the UD116 bill concern different areas […]

MDR amendment signed into law: how will Polish tax scheme reporting change from 1 October 2026?

The amendment does not abolish MDR reporting altogether. However, the Polish legislator is moving away from solutions that went beyond the EU standard resulting from the DAC6 Directive. In practice, this means, above all, abolishing the obligation to report domestic tax schemes and focusing the reporting regime on cross-border arrangements. For many businesses, this will be a genuine simplification. Until now, […]

Evidence requests in Polish tax proceedings – when can the tax authority refuse to admit evidence?

Taxpayers have the right to contribute to the evidentiary record One of the fundamental principles of Polish tax proceedings is the obligation to establish the facts of the case thoroughly and accurately. The tax authority must take all necessary steps to determine the actual circumstances relevant to the outcome of the case. This does not mean, however, that only the […]

Acceptance protocols and the timing of service performance for VAT purposes in Poland

The nature of the dispute: performance vs. acceptance The case concerned a taxpayer providing IT implementation and system upgrade services. The projects were delivered in stages, with each stage subject to formal acceptance by the client. Acceptance was documented through protocols signed after the client had verified the work and had the opportunity to raise objections. The contractual model included: […]