Taxation Omnibus: Tax simplification package to streamline compliance and enhance competitiveness of the Single Market

On 24 June 2026, the European Commission presented two draft legal acts: Taxation Omnibus and a proposal amending the Directive on administrative cooperation in the field of taxation (DAC). The key measures to be introduced include an exemption from withholding tax (WHT) on all cross-border payments of dividends, interest, and royalties between companies in the EU, as well as simplifications related to residence certificate procedures and tax refunds. Furthermore, the Omnibus provides for ATAD simplifications and removes overlapping provisions between the Controlled Foreign Company (CFC) rules and the global minimum tax (Pillar Two). Both proposals have been submitted to the European Parliament for an opinion and will then be sent to the Council of the EU for adoption.

On 19 June 2026, tax guidelines were published on the taxation of revenue from statutory indexation of funds held in bank accounts or named accounts of members of cooperative savings and credit unions. According to the guidelines, revenue from the indexation of funds held in bank accounts or named accounts of members of cooperative savings and credit unions (SKOK) constitutes capital gains. The revenue arises when the indexation amount is “credited” to the bank account or SKOK account, not when the funds are paid out. The tax must be collected by the bank or the cooperative savings and credit union, acting as remitters.

From 20 June 2026, amendments to the SENT monitoring system have been in force, reducing compliance obligations for the clothing and footwear sectors. Transports carried out under domestic sales between businesses, intra-Community supplies of goods (with one exception), exports outside the EU and humanitarian aid have been exempted from the reporting requirement. At the same time, the reporting thresholds have been increased: for clothing (CN chapters 61–63) from 10 kg to 31.5 kg, and for footwear from 20 to 64 pairs. In addition, the list of clothing parts and accessories covered by selected CN codes that are excluded from monitoring has been clarified, while the existing exclusion for certain types of footwear has been maintained.

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In its judgment of 23 June 2026 (case file III FSK 404/25), the Supreme Administrative Court held that the assessment of liability with respect to the levy on foodstuffs must relate to the final drink placed on the market. The Court emphasised that the substances subject to the levy do not lose their natural character merely because they are incorporated into the drink as part of a plant extract, including guarana extract containing caffeine.

Last week, an Act which removes the obligation to report domestic tax arrangements (MDR) and at the same time introduces a number of amendments to the Tax Code and other statutes, was published in the Polish Journal of Laws. The amendments cover, among other matters, rules on the competence of tax authorities, tax refunds and overpayments, service of documents, corrections of tax returns, payment of tax by another entity and taking evidence remotely. The changes also affect cross-border MDR, the obligations of promoters, and criminal fiscal liability for late filing of MDR-3 and MDR-4. The Act is to enter into force on 1 October 2026.

On 23 June 2026, an Act amending the Tax Code was published in the Polish Journal of Laws. According to the Act, individual rulings issued by competent local government tax authorities are to be published (in anonymised form) in a single, unified, and publicly accessible database of tax rulings.             

The database will be available in the Public Information Bulletin on the website of the office serving the Minister of Finance. Currently, this function is performed by the EUREKA Customs and Tax Information System. The Act is to enter into force on 24 September 2024.

In reply to parliamentary inquiry no. 17096 dated 3 June 2026, the Minister of Finance and Economy explained that for a correcting invoice reducing the amount due, which has been issued outside the KSeF (National e-Invoicing System), but has been effectively delivered to the purchaser, the accounting period in which the input tax must be reduced begins with the actual receipt of the invoice. This also applies to situations where the original invoice was issued in a structured form. The Minister indicated that a seller’s later submission of such a corrective invoice to the National e-Invoicing System does not affect the timing of the adjustment on the purchaser’s side. Different rules may apply only in specific cases provided for in the VAT Act, such as system failure, unavailability of KSeF or use of the offline mode. It was also stated that the Ministry of Finance does not intend to issue a general tax ruling or tax guidelines in this area and does not consider it necessary to clarify the provisions of the VAT Act.

On 25 June 2026, general ruling no. DD4.8201.2.2026 was published, relating to the application of double taxation treaties (DTTs) to seafarers being Polish tax residents, especially in the context of the Polish‑Norwegian DTT. The Minister clarified that the mere fact that a seafarer is not subject to limited tax liability abroad, or that no tax is actually paid in the paying country, does not in itself constitute a basis for refusing to apply the double taxation treaty and the method of avoiding double taxation arising from that agreement. The ruling concerns a situation in which a seafarer who is a Polish tax resident does contract work on board a sea‑going vessel operated in international transport by a Norwegian enterprise. The Ministry pointed out that what is decisive is whether the conditions set out in Article 14(3) of the treaty are satisfied, rather than whether Norway in practice exercises its right to tax that income. The ruling also stressed that the interpretative principles presented may be applied, as appropriate, to other double taxation treaties to which Poland is a party, provided that, in the case in question, the conditions for applying the relevant convention are met.