Report highlights the changing realities of tax controls in Poland

A report published in June 2025 by MDDP in cooperation with the Polish Lewiatan Confederation provides a comprehensive overview of recent trends in tax audits, tax verification activities, and tax proceedings in the country. Business Under the Tax Microscope – Poland, which covers 2019–24, highlights several key implications for businesses.

In Poland, a taxpayer may be subject to two types of audits:

• Tax inspections; or

• Customs and fiscal inspections.

Customs and fiscal audits are more detailed and grant authorities broader powers.

As the data in the report shows, the significance of customs and fiscal audits has grown in recent years, while the number of tax audits has declined. Audits tend to be lengthy: on average, a customs and fiscal audit lasted 332 days, whereas a tax audit lasted 113 days. They often conclude with substantial findings, with single customs and fiscal audits identifying an average of PLN 1.2 million in liabilities, while a tax audit averaged PLN 195,000. However, a positive development is that audits are increasingly conducted online, reducing their impact on day-to-day business operations.

Tax inspections are most often initiated without prior notice, despite statutory requirements. The taxpayer was notified beforehand in only 11% of cases. This leaves taxpayers little opportunity to prepare or adjust tax returns, as corrective actions are blocked by law during the audit.

The effectiveness of the tax authorities is very high: in 2024, irregularities were detected in 98% of completed tax audits and 94% of customs and fiscal audits. This is supported by advanced analytical tools. Authorities increasingly rely on digital systems such as VAT JPK (SAF-T), data warehouses, STIR (an automatic system for analysing transaction data from financial institutions), and, soon, KSeF (an e-invoicing system) and CIT JPK (SAF-T for corporate income tax, or CIT).

Once an audit is initiated, taxpayers should pay close attention to the explanations and documents they provide. In many cases, support from professional representatives is beneficial.

VAT remains the most frequently audited tax in Poland, accounting for over half of all audits. The highest-risk groups include taxpayers engaged in international transactions, online sales, and businesses operating in the construction, transport, IT, hospitality, electronics trade, and fuel sectors.

Only 10% of all audits focused on CIT. However, this is expected to change. The Ministry of Finance has announced increased activity in the areas of transfer pricing and withholding tax. The establishment of a dedicated team in 2025 to combat aggressive tax planning signals the direction of future efforts, with particular attention on multinational corporate groups.

Changing audit realities make it increasingly important for companies to implement procedures in case of an audit, properly train staff, and conduct regular internal tax reviews. This enables businesses to better prepare for potential tax authority actions and reduce the risk of identified irregularities.

The Polish National Revenue Administration (KAS) can verify a taxpayer’s reporting through verification activities. While these procedures share the goals of formal audits, they are less formalised.

Verification activities are very common. In Poland, more than 20 are initiated every minute. Data from 2024 shows that the highest value of identified tax arrears was recorded under this procedure – exceeding the total from all audits combined. Verification activities can also serve as a precursor to a full inspection, and therefore should not be ignored.

‘Entrepreneurs’ (przedsiębiorcy) often appreciate verification activities because they are conducted quickly and informally – via phone or email – and typically do not cause significant disruption to business operations.

It is common in Poland for disputes with tax authorities to reach administrative courts. Data indicates that almost all adverse second-instance decisions are appealed to administrative courts. Court proceedings are time-consuming but provide an essential guarantee of independent review of tax authority decisions.

Importantly, courts do not conduct evidentiary proceedings, so it is crucial that all supporting evidence be presented during the initial proceedings before the tax authorities.

The report underscores the growing importance of managing the tax function proactively. The scale and intensity of audits demand that companies operate in a structured, consciously managed manner rather than reactively. In today’s environment, this approach allows businesses to minimise default interest liabilities, management board responsibility, and potential disputes with KAS.

From the perspective of businesses, the greatest challenges in the Polish tax system remain the complexity of tax laws, their frequent amendments, and occasionally inconsistent interpretations by authorities. These factors increase the risk of uncertainty in tax settlements. At the same time, a growing number of businesses are turning to compliance tools and solutions aimed at enhancing tax security, such as tax rulings, cooperative compliance programmes, and protective opinions.

The ongoing digitalisation of Poland’s tax administration is viewed positively. Today, the vast majority of cases can be handled online, and planned solutions will introduce even greater automation and transparency. While these changes require companies to adapt, they also significantly simplify ongoing interaction with the tax authorities.