Improving relations with tax authorities and audit officers is one of the most frequently raised demands by Polish entrepreneurs. As part of the government’s deregulatory efforts, businesses are calling for greater cooperation and openness from tax officials, clearer interpretations of regulations, more respectful treatment, and a shorter statute of limitations. These changes, they argue, could foster a healthier atmosphere for dialogue between businesses and the state.
“Both tax authorities and taxpayers are looking for more dialogue, faster communication, and quicker resolution of doubts regarding settlements,” said Jakub Warnieło, tax advisor and head of the Tax and Litigation Team at MDDP, in an interview with Newseria. “Entrepreneurs expect tax officials to explain what is happening during proceedings, when the process ends, and to show more willingness to hear their arguments. The prevailing perception is still that entrepreneurs are treated as supplicants rather than clients of the National Revenue Administration (KAS), despite years of reform.”
The MDDP report titled “Entrepreneurs under the Tax Microscope: Difficult Relations Between Taxpayers and Authorities,” created in cooperation with the Lewiatan Confederation, highlights widespread dissatisfaction among business owners. Entrepreneurs criticize unclear and frequently changing tax laws, legal uncertainty, and what they perceive as a lack of partnership from tax authorities, all of which hinder long-term business planning.
“Although the report mainly concerns tax inspections, we expect a paradigm shift in the coming years. Tax settlements will increasingly be monitored in real time using digital tools already available to the authorities. Tax officials essentially have all the data on hand, and the focus will shift toward rapid communication and clarification of doubts rather than long, drawn-out inspections,” added Warnieło.
According to the report, between 2019 and 2024, Polish authorities launched an average of 59 tax audits and 18 customs-tax inspections per working day. The role of customs-tax inspections has been rising significantly—quadrupling over five years—while traditional tax audits have declined by 40% in just two years. Most inspections are initiated without prior notice, and their duration often significantly exceeds statutory limits. In 2024, 98% of tax audits and 94% of customs-tax inspections resulted in the identification of irregularities.
“With such a high rate—over 95%—of audits confirming irregularities, one must ask whether tax authorities are truly excellent at selecting cases, or whether there’s an unspoken rule that every audit must uncover something,” Warnieło noted. “Entrepreneurs should be aware that the authorities already know a great deal about them and aren’t acting blindly. Most of the data comes from the businesses themselves.”
The most frequently used instrument by tax authorities remains preliminary tax checks, with 12 million conducted between 2019 and 2024—equivalent to 20 new checks every minute.
“There is a concern about overuse of these checks, but the issue is more legal than practical. Preliminary checks are less burdensome than full tax audits and often end with the matter being resolved,” said Andrzej Nikończyk, Chair of the Tax Council at the Lewiatan Confederation. “The current regulations do not reflect today’s digital reality. With the advent of the National e-Invoicing System, tax authorities will soon know not only which invoices were issued, but also their content. The regulations must catch up.”
Digitization is the only area where entrepreneurs gave more positive than negative feedback. However, they also expressed concerns about implementation timelines. The shift to digital reporting involves costs and requires a testing phase.
“There needs to be an adequate adjustment period to avoid costly errors,” Nikończyk stressed. “Once an invoice with mistakes is issued to consumers, it’s nearly impossible to fix. That’s why businesses are cautious and demand that everything works correctly from the start. This requires a longer vacatio legis and overall legal stability.”
Business owners also want reform in the statute of limitations for tax liability. Currently, the five-year period for document verification is often extended, causing uncertainty.
“There’s also a case to be made for shortening this period, especially in cases involving simple errors that automated systems could detect. If no issues are flagged within five years, they should be left untouched. This would increase taxpayer certainty,” Nikończyk emphasized.
The MDDP and Lewiatan Confederation report was presented at the 9th Tax Council Congress held on June 10–11 in Warsaw. The event brought together experts, business leaders, tax advisory firms, and tax administration representatives to discuss the most pressing changes in the tax system affecting Polish businesses. The congress was covered by Newseria as a media partner.