The War Nobody Wants
No entrepreneur wakes up in the morning thinking: today I’d like to enter a dispute with the tax office. Tax disputes are not a goal—they are a cost of doing business in a system that offers no clear answers.
And yet disputes happen. They happen even to those who do everything right. Because “right” is a relative concept, and its definition belongs to whoever is doing the controlling.
Hayek wrote that freedom consists in not being subject to the arbitrary will of another. In a tax dispute, this subjection becomes tangible. An official decides whether your accounting is correct. An official decides whether to initiate proceedings. An official decides how long they will last and how they will end.
You may be right. You may have the documents. You may have case law on your side. But they have the power.
The Anatomy of Conflict
A tax dispute begins long before you know about it.
Somewhere in the system, a light blinks on. An algorithm flags an anomaly. An analyst spots a pattern. Information from a competitor reaches the right hands. And suddenly you’re on a list.
The first audit looks innocent. Preliminary inquiries. A request for documents. A few questions. Most entrepreneurs treat it as a formality—irritating but temporary.
This is a mistake.
At this moment, the picture of your case is taking shape. What you say will be recorded. What you don’t say will be interpreted. The documents you provide will be analyzed not to confirm that you’re right—but to find grounds for further action.
Carl Schmitt defined politics through the distinction between friend and enemy. In a tax dispute, this distinction is clear from day one—even if no one says so aloud.
The Psychology of Siege
An entrepreneur in a tax dispute experiences what psychology calls a state of siege. The threat is real but diffuse. You don’t know where the next blow will come from. You don’t know how long it will last. You don’t know what else they know.
In this state, people react in one of two ways. Some freeze—they stop acting, wait, hope it will somehow resolve itself. Others charge—they argue about everything, escalate every conflict, treat every letter as an attack requiring immediate riposte.
Both approaches are wrong.
Freezing surrenders initiative to the opponent. Charging exhausts resources and closes off negotiating possibilities. Effective defense requires something different: strategic patience combined with tactical firmness.
Knowing when to stay silent. Knowing when to speak. Knowing when to yield on a small matter to win the larger one. Knowing when to escalate—and to what level.
This is not intuitive. It requires experience.
False Choices
The tax system offers apparent alternatives.
Cooperate or defend? A false choice. One can cooperate strategically—respond to what is required, remain silent where permitted, control the flow of information.
Admit or fight? A false choice. One can negotiate terms, seek intermediate solutions, voluntarily submit to liability on one’s own conditions.
Pay or go to court? A false choice. One can challenge part of a decision and accept the rest. One can pay under compulsion while simultaneously pursuing a refund. One can play on multiple levels at once.
The world is not binary. The system wants you to think it is—because binary choices are easier to control. But law is full of shades of gray. And in those shades lie possibilities.
The Value of Time
Time in a tax dispute works differently for different parties.
For the authority, time is neutral. The official does not pay for each month the proceedings last. They do not lose clients, do not have to explain themselves to a bank, do not wake at night thinking about what happens if they lose.
For the entrepreneur, time is a resource that depletes. Every month of uncertainty is a cost—financial, emotional, reputational. Every year of dispute is a year that could have been spent building, not defending.
That is why temporal strategy is crucial. Sometimes one must accelerate—force a decision, challenge delay, refuse to be drawn into a war of attrition. Sometimes one must slow down—wait for a favorable change in regulations, for new case law, for a change in the panel of judges.
There is no universal answer. There is only analysis of the specific situation and selection of the optimal path.
The Entrepreneur’s Solitude
There is an aspect of tax disputes rarely discussed: isolation.
An entrepreneur in a dispute with the treasury is alone. Employees don’t understand what’s happening. Family sees only stress and absence. Counterparties begin to distance themselves—because no one wants to be close to someone who has problems with the authorities.
This solitude is part of the pressure. The system knows that an isolated person is weaker. That they are easier to break when they have no support. That they will sooner sign a settlement they shouldn’t sign if they feel no one stands with them.
A professional representative is not just legal knowledge. It is also presence. Someone who understands what you’re going through—because they’ve seen it dozens of times. Someone who assumes part of the burden so you can function. Someone who tells you the truth, even when the truth is hard.
In a war you didn’t want, you need someone on your side.
The Limits of the System
The tax system holds enormous power. But it is not omnipotent.
There are procedures it must follow. There are deadlines that bind it. There is evidence it must present. There are courts that review it. There is European law that stands above national law.
The Court of Justice of the EU has repeatedly corrected Polish practice. The Supreme Administrative Court overturns every fourth challenged decision. The Ombudsman intervenes in cases of systemic violations.
These mechanisms work—but only for those who use them. Rights that are not enforced are theoretical rights. Guarantees you don’t invoke are guarantees that don’t exist.
The system counts on you giving up. On exhaustion winning. On the costs of fighting exceeding the costs of surrender.
Sometimes that’s how it is. But sometimes—more often than you think—the fight pays off.
What We Do
We conduct tax litigation from the first signal to the final resolution. Audits, proceedings, appeals, administrative courts, the Supreme Administrative Court. If necessary—the Court of Justice of the EU and the European Court of Human Rights.
We do not promise victory in every case. We promise that your case will be handled with full understanding of what tax litigation is—not merely a legal procedure, but a human experience.
We analyze files and build strategy. We represent clients in interrogations and at hearings. We negotiate where negotiation makes sense. We fight where fighting is the only option.
We also help in cases that appear hopeless—because sometimes the worst position is only apparently the worst.
A Final Thought
A tax dispute is a test. A test of a system that should serve citizens but sometimes serves only itself. A test of an entrepreneur who must find the strength to fight for what is theirs. A test of law that protects on paper but in practice requires defense.
No one wants this war. But when it comes—it must be waged.
Better not to wage it alone.
