B2 Tax Appeals and Complaints to Administrative Courts

News
Liability of Directors of Foreign Companies for Tax Obligations in Poland
2026-09-19

Category: Taxes and Tax Disputes

Liability of Directors of Foreign Companies for Tax Obligations in Poland

Polish tax law permits the arrears of a legal person to be transferred, by administrative decision,…

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Tax Overpayment Recovery in Poland. A Practitioner’s Guide for Foreign Clients
2026-05-18

Category: Taxes and Tax Disputes

Tax Overpayment Recovery in Poland. A Practitioner’s Guide for Foreign Clients

The recovery of overpaid Polish tax is, on its surface, a simple proposition: the State has…

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The Tax Office That Cried Wolf
2026-04-06

Category: Taxes and Tax Disputes

The Tax Office That Cried Wolf

 Seven Years, Two Witnesses, and Nothing to Show for It In the autumn of 2021, a…

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The Binding Force of CJEU Jurisprudence in Domestic Tax Law
2026-04-05

Category: Taxes and Tax Disputes

The Binding Force of CJEU Jurisprudence in Domestic Tax Law

Remedies for Taxpayers Confronting National Noncompliance with EU Law The accession of Member States to the…

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The Ineffectiveness of Voluntary Disclosure Under Polish Fiscal Penal Law
2026-03-31

Category: Taxes and Tax Disputes

The Ineffectiveness of Voluntary Disclosure Under Polish Fiscal Penal Law

When Article 16 of the Fiscal Penal Code Fails to Shield the Offender? Voluntary disclosure (czynny…

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The Principle of In Dubio Pro Tributario
2026-02-15

Category: Taxes and Tax Disputes

The Principle of In Dubio Pro Tributario

In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…

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Taxpayer-Favorable Interpretation Doctrine in Polish Administrative Tax Jurisprudence
2026-02-15

Category: Taxes and Tax Disputes

Taxpayer-Favorable Interpretation Doctrine in Polish Administrative Tax Jurisprudence

I. Introduction Many entrepreneurs regard the principle of in dubio pro tributario as a trump card…

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When May the Tax Authority Inspect Your Bank Account?
2026-02-12

Category: Taxes and Tax Disputes

When May the Tax Authority Inspect Your Bank Account?

I. Introduction: The Tension Between Fiscal Efficiency and Financial Privacy Few questions in modern tax law…

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The Statute of Limitations on Mortgage-Secured Tax Obligations
2026-02-12

Category: Taxes and Tax Disputes

The Statute of Limitations on Mortgage-Secured Tax Obligations

Polish Courts and the Expanding Doctrine of Manifest Unconstitutionality How the Kielce Administrative Court’s 2023 Ruling…

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Statute of Limitations for Tax Obligations
2026-02-12

Category: Taxes and Tax Disputes

Statute of Limitations for Tax Obligations

Statute of Limitations for Tax Obligations (Ger. Verjährung von Steuerschulden; Fr. prescription fiscale) – The statute of…

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Tolling and Interruption of the Statute of Limitations on Tax Obligations: When the Fisc Buys Time
2026-02-12

Category: Taxes and Tax Disputes

Tolling and Interruption of the Statute of Limitations on Tax Obligations: When the Fisc...

When the Fisc Buys Time The statute of limitations on tax obligations constitutes one of the…

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The Exclusionary Rule in Tax Proceedings: Judicial Scrutiny of Wiretap Evidence
2026-01-25

Category: Taxes and Tax Disputes

The Exclusionary Rule in Tax Proceedings: Judicial Scrutiny of Wiretap Evidence

Tax authorities may not uncritically accept evidentiary materials transmitted by prosecutorial offices or intelligence services. Where…

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Seizure of Company Assets Without a Court Judgment
2026-01-19

Category: Pending Classification

Seizure of Company Assets Without a Court Judgment

The Constitution of the Republic of Poland guarantees that forfeiture of property may occur only on…

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Prejudgment Security Over Taxpayer Assets Must Rest on Justified Grounds
2026-01-19

Category: Taxes and Tax Disputes

Prejudgment Security Over Taxpayer Assets Must Rest on Justified Grounds

Prejudgment security over taxpayer assets presents an instrument of dual character: on one hand, it safeguards…

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Preconditions for Prejudgment Security Over Business Assets
2026-01-19

Category: Taxes and Tax Disputes

Preconditions for Prejudgment Security Over Business Assets

When May Tax Authorities Encumber a Taxpayer’s Property? Prejudgment security over business assets represents one of…

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How the Tax Office Enforces Tax Liabilities in Poland
2026-01-19

Category: Pending Classification

How the Tax Office Enforces Tax Liabilities in Poland

When the Tax Authority Comes Knocking Asset seizure by the tax office represents the ultimate coercive…

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Evidence in Tax Proceedings
2026-01-19

Category: Taxes and Tax Disputes

Evidence in Tax Proceedings

Evidence in tax proceedings encompasses the totality of evidentiary instruments employed to establish the factual predicate…

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The Principle of Free Evaluation of Evidence in Tax Proceedings
2026-01-19

Category: Taxes and Tax Disputes

The Principle of Free Evaluation of Evidence in Tax Proceedings

The principle of free evaluation of evidence constitutes the cornerstone of fact-finding in tax proceedings, establishing…

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Evidentiary Standards and the Duty to Gather Evidence in Polish Tax Proceedings
2026-01-19

Category: Taxes and Tax Disputes

Evidentiary Standards and the Duty to Gather Evidence in Polish Tax Proceedings

The principles governing the gathering of evidentiary material constitute the foundation of fair and lawful tax…

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Revocation and Modification of Final Tax Decisions
2026-01-18

Category: Taxes and Tax Disputes

Revocation and Modification of Final Tax Decisions

Extraordinary Remedies Under Polish Tax Procedure The revocation or modification of a final tax decision constitutes…

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Annulment of Tax Decisions
2026-01-18

Category: Taxes and Tax Disputes

Annulment of Tax Decisions

Doctrinal Foundations, Comparative Frameworks, and Procedural Mechanisms The annulment of a tax decision (Aufhebung des Steuerbescheids…

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The Evidentiary Burden in Tax Proceedings
2026-01-16

Category: Taxes and Tax Disputes

The Evidentiary Burden in Tax Proceedings

Official Documents, Counter-Evidence, and the Limits of Administrative Discretion This Article examines a landmark decision by…

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The Rationale of Tax Decisions Under Polish Law
2026-01-16

Category: Taxes and Tax Disputes

The Rationale of Tax Decisions Under Polish Law

The statement of reasons accompanying a tax decision constitutes far more than a mere formality—it represents…

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Defective Judicial Reasoning as Both Sword and Shield in Administrative Tax Litigation
2026-01-15

Category: Taxes and Tax Disputes

Defective Judicial Reasoning as Both Sword and Shield in Administrative Tax Litigation

The Jurisprudence of Reasoned Decision-Making A certain tax dispute concerning undisclosed sources of income persisted for…

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Administrative Dilatoriness and the Right to Interest on Tax Overpayments
2026-01-12

Category: Taxes and Tax Disputes

Administrative Dilatoriness and the Right to Interest on Tax Overpayments

Causation, Contribution, and the Limits of Fiscal Immunity Abstract: This article examines a consequential ruling by…

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Reopening of Tax Proceedings
2026-01-12

Category: Taxes and Tax Disputes

Reopening of Tax Proceedings

When Previously Known Circumstances Cannot Justify Resumption of a Final Determination The reopening of tax proceedings…

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Foreign Tax Credit for Dividend Income
2026-01-12

Category: Taxes and Tax Disputes

Foreign Tax Credit for Dividend Income

The Full 19% Statutory Rate Prevails Over Treaty Limitations Polish taxpayers may reduce their withholding tax…

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The Statute of Limitations on Tax Obligations and the Decisive Moment of Service
2026-01-12

Category: Taxes and Tax Disputes

The Statute of Limitations on Tax Obligations and the Decisive Moment of Service

Pursuant to Article 70 § 1 of the Polish Tax Ordinance, tax obligations become time-barred upon…

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Cassation Appeals to the Supreme Administrative Court of Poland
2026-01-11

Category: Litigation and Precedents

Cassation Appeals to the Supreme Administrative Court of Poland

Introduction An unfavorable judgment from the Voivodeship Administrative Court need not constitute the terminus of administrative…

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Tax secrecy, tax advisor-client privilege, banking secrecy and other legally protected confidentiality rights in tax proceedings
2025-12-08

Category: Taxes and Tax Disputes

Tax secrecy, tax advisor-client privilege, banking secrecy and other legally protected confidentiality rights in...

  Tax secrecy (Steuergeheimnis, secret fiscal), tax advisor-client privilege (Steuerberatergeheimnis, secret professionnel du conseiller fiscal), and…

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