The year 2026 will bring significant changes to the Polish Tax Ordinance. Some of them are deregulatory and clarifying in nature, but many will have a direct impact on the day-to-day tax compliance of businesses. Particular attention should be paid to changes in mandatory disclosure rules (MDR), amended rules for correcting tax returns, overpayment procedures, powers of attorney, and communication with tax authorities.
For companies, this means above all the need to update internal tax procedures, review document workflows, and prepare accounting teams for new deadlines and formal requirements.
The key change: reduced MDR obligations
As of 1 October 2026, the obligation to report tax schemes will be significantly limited. Under the new rules, tax schemes within the meaning of the Polish Tax Ordinance will generally cover only cross-border arrangements. In practice, this means that the obligation to report so-called domestic tax schemes will be abolished.
This is an important simplification for entrepreneurs, advisors, and accounting offices. However, it does not mean that MDR obligations will disappear entirely – reporting duties related to cross-border arrangements will remain in place, and the relevant definitions will be clarified.
Changes to tax return corrections and overpayments
The amendment simplifies the procedure for correcting tax returns where an overpayment arises. If the overpayment results directly from a corrected return filed after the original deadline, the taxpayer will no longer be required to submit a separate application for the confirmation of the overpayment. The date of filing the correction will be treated as the date on which the procedure is initiated.
At the same time, a new obligation will be introduced: if a corrected return shows an overpayment exceeding PLN 10,000, the taxpayer will have to attach a written explanation of the reasons for the correction. For lower amounts, providing such an explanation will be optional.
Broader possibilities to act through a proxy
The changes also cover the rules on powers of attorney. A power of attorney to sign tax returns is expected to also include the ability to submit ZAW-NR notices. In addition, persons who are not parties to proceedings but are summoned to provide explanations or documents will be able to appoint a proxy.
For entrepreneurs and accounting offices, this may mean more efficient handling of tax matters and a reduced need to grant additional, special powers of attorney in selected situations.
Easier communication with tax authorities
The new rules provide, among other things, for the possibility of remote hearings of parties and witnesses, clarification of delivery rules, and an increase in the threshold up to which a tax authority may correct a tax return ex officio during verification activities – from PLN 5,000 to PLN 10,000.
After making such a correction, the authority will no longer have to send a full copy of the corrected tax return. It will be sufficient to provide clear information on the reasons for the correction, the new amount of tax due or refundable, and instructions on the right to object.
Tax rulings in a single EUREKA database
From 24 September 2026, individual tax rulings issued by local government tax authorities concerning local taxes and fees are to be published in one nationwide EUREKA database. This will apply, among others, to rulings concerning real estate tax, agricultural tax, and local fees.
This is an important change for taxpayers owning real estate, operating in multiple locations, or analysing the practice of different municipalities. The centralisation of rulings should make it easier to compare the positions of authorities and assess tax risk.
Summary
The planned changes to the Polish Tax Ordinance may be seen as a step towards simplifying certain formal obligations, especially in the areas of MDR and overpayments. At the same time, entrepreneurs should remember that simplification does not remove the need for ongoing control over tax settlements. In many cases, what will change is not so much the taxpayer’s responsibility itself, but rather the way in which certain actions are documented and communicated to tax authorities.
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