#1 New Rights for Taxpayers During Audits

On 1 October 2025, amendments to the Act on the National Revenue Administration and the Value Added Tax Act will enter into force (Act of 24 June 2025 amending the Act on the National Revenue Administration and the Value Added Tax Act, Journal of Laws, item 894).

Filing an Initial Tax Return During an Audit

The amended provisions will allow taxpayers to submit an initial (i.e. original) tax return, even if a customs and fiscal audit has already begun. Previously, this was not permitted. Taxpayers will now have 14 days from the start of the audit to file an initial return if they had not done so earlier or after the conclusion of the customs and fiscal audit, if the return was not filed either before or during the audit.

Correcting Returns After the Audit

Following the conclusion of the audit, taxpayers will also be allowed to submit a correction to the return. This correction may be limited only to those areas where the taxpayer agrees with the findings of the tax authority. This change replaces the previous "all-or-nothing" rule, where a full tax proceeding had to be initiated even if the taxpayer only partially disagreed with the audit findings and was willing to submit a correction for the remaining, undisputed issues.

Partial Corrections Now Possible

Tax authorities will now be authorised to accept partial corrections that reflect only the undisputed findings. As a result, formal tax proceedings should be limited solely to the matters still in dispute.

#2 Higher VAT Exemption Threshold for Small Businesses

Currently, entities with their principal place of business in Poland may qualify for the so-called subjective exemption from VAT, provided that their turnover does not exceed PLN 200,000 (excluding VAT) in either the previous or current calendar year. From 1 January 2026, the threshold will increase to PLN 240,000 (excluding VAT).

Not All Activities Qualify

The turnover-based exemption is not available to all small businesses. The VAT Act excludes certain categories of activity, including legal practitioners, tax advisors, jewellers, debt collection agencies, and businesses selling building plots, new means of transport, or excise goods (with certain exceptions).

Monika deals with day-to-day services and support for business entities in the field of indirect taxes with particular emphasis on value added tax.

Prof Avv Raffaele Torino

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