Tax proceedings

On 11 February 2026, the General Court of the EU delivered its judgment in Case T-689/24, which had been brought following a request for a preliminary ruling from the Supreme Administrative Court concerning the interpretation of the provisions of the VAT Directive relating to VAT deduction.

Receiving an unfavourable tax decision from the second-instance authority does not necessarily mean a definitive defeat in a dispute with the tax authorities. The taxpayer has the right to appeal against such a decision to the Provincial Administrative Court (WSA). It should be emphasised, however, that the effectiveness of judicial protection is strictly dependent on compliance with strict deadlines and the fulfilment of formal requirements, which are subject to meticulous scrutiny at the preliminary stage of administrative court proceedings.  

On 4 April 2025, the Polish Parliament passed a law reducing health insurance contributions for entrepreneurs. This is due to come into effect on 1 January 2026. However, it should be noted that further proceedings are required for the law to be enacted.

Protective opinions issued by the Head of the National Tax Administration (KAS) are an important tool for providing legal certainty to taxpayers. Faced with potential tax proceedings, taxpayers can apply for such opinions, which protect them from the risk that their actions will be considered an attempt to circumvent tax law. In our latest blog post, we will take a look at some of the significant decisions of the Head of KAS in recent months regarding issues such as restructurings, reduction of depreciation rates, simplification of ownership structure or cross-border mergers. We will analyze both the content of these decisions and their economic context to show how these opinions affect everyday business practices and tax management.

Taking advantage of the Polish Investment Zone’s preferences is an attractive option for investors seeking tax benefits, but such benefits are not without risk. Recognition of eligible costs, inability to take advantage of simplified transfer pricing documentation, and potential revocation of support decisions are just some of the issues that can expose entrepreneurs to unexpected complications. In our latest blog post, we examine these risks and the Polish Investment Zone rules to help investors better understand what these preferences may mean for their business operations.