Poland: Tax deregulation proposals and court decisions

The KPMG member firm in Poland prepared a July 2026 report summarizing recent tax developments, including:

• Reform of National Labour Inspectorate: New rules strengthen the powers of the National Labour Inspectorate (PIP) to review forms of engagement, including the power to issue administrative decisions confirming the existence of an employment relationship. 
• Tax Deregulation 2.0: The Ministry of Finance on July 6, 2026, presented a proposed package of tax deregulatory measures that would include introducing electronic receipts (e-receipts), providing pre-completed value added tax (VAT) returns for approximately 2 million taxpayers, extending the deadline for filing an appeal to 30 days, and introducing a five-year validity period for tax rulings.
• Simplifications to ESG reporting: The government in July 2026 published a proposed bill amending the Accounting Act that would simplify ESG reporting by limiting obligations to entities with more than 1,000 employees and revenues exceeding PLN 1.9 billion, with a proposed effective date of January 1, 2027.
• Bill amending Trade Unions Act: The government on July 10, 2026, submitted a proposed bill to the Sejm that would allow electronic communication and information exchange between employers and trade unions, which would become effective 14 days after publication in the Journal of Laws.
• Limiting greenwashing and consumer protection: The government on July 10, 2026, submitted a proposed bill to the Sejm amending the Act on Counteracting Unfair Market Practices and the Consumer Rights Act that would restrict environmental labeling to recognized certification schemes and prohibit generic environmental claims.
• SAC decision on dividend tax exemption: The Supreme Administrative Court (SAC) on July 8, 2026, held (case file II FSK 185/25) that the corporate income tax (CIT) exemption under Article 22(4) of the CIT Act applies only when shares in the dividend-paying company are held directly, excluding indirect ownership structures.
• SAC decision on zone income records: The SAC on July 8, 2026, held (case file II FSK 1082/23) that a taxpayer may maintain a single record for income exempt in a special economic zone (SEZ) and under an investment support decision.
• SAC decision on company cars: The SAC on July 7, 2026, held (case file II FSK 1034/23) that making company cars available to shareholders for private purposes represents income from hidden profits, regardless of whether the company generates a profit or incurs a loss.
• CJEU decision on liability of VAT representative: The Court of Justice of the European Union (CJEU) on July 8, 2026, held (case T-356/25) that joint and several liability cannot be attributed to a tax representative solely by virtue of holding that role, when they did not participate in the taxable transactions and acted in good faith.
• Tax Freedom Day: Symbolically, taxpayers in Poland celebrated Tax Freedom Day on July 9, 2026, indicating that 189 days of the year were devoted to paying public levies based on public sector expenditure reaching approximately 51.8% of gross domestic product (GDP).