The Certainty of Uncertainty
Benjamin Franklin wrote in 1789 that in this world nothing is certain except death and taxes. He was right—but not entirely. Death is certain and predictable: it comes once, at a definite moment, and is final. Taxes are certain but unpredictable: they come repeatedly, in shifting forms, and you never know whether what you paid was what you should have paid.
Were Franklin alive in Poland today, he would likely add a third certainty: that tax regulations will change before you have time to understand them.
Leviathan and Its Appetite
Hobbes called the state Leviathan—a monster that protects citizens from chaos but itself requires feeding. Taxes are Leviathan’s sustenance. The larger the monster, the larger the appetite.
Poland’s tax administration makes no secret of its ambitions. The Ministry of Finance publishes plans, sets targets, measures efficiency. In 2014, the fiscal control apparatus “achieved 105% of its quota.” A quota for what? For proceedings concluded with a determination of tax liability.
This is a system that has KPIs. And the KPI is your tax obligation.
Total liabilities determined in decisions that year amounted to 10.6 billion zlotys—64% more than the year before. Asset security measures against taxpayers rose 71%. Forty thousand criminal fiscal penalties were imposed.
These are not statistics. This is fiscal policy expressed in numbers.
Asymmetry as Principle
John Stuart Mill wrote of the tyranny of the majority. In tax law, we encounter something more subtle: the tyranny of asymmetry.
A tax authority can be wrong without significant consequences. It loses a case in court—and nothing happens. No official loses a job, no budget suffers, no career collapses.
A taxpayer who is wrong pays interest, penalties, sometimes faces criminal liability. A taxpayer who is right but cannot prove it pays the same. A taxpayer who is right and proves it pays with the costs of proceedings, years of uncertainty, frayed nerves.
In this game, one side risks points. The other risks existence.
Locke argued that the power of the state rests on the consent of the governed. But did anyone consent to a system in which proving one’s innocence takes five years and costs a fortune?
Natural Law and Tax Law
Aquinas distinguished between natural law and positive law. Natural law is discovered by reason; positive law is created by authority. Tax law belongs to the latter category—and radically so.
There is nothing “natural” about a 23% VAT rate. There is nothing “rational” about the same expenditure being deductible in one situation and not in another. There is no deeper logic in an appeal deadline of fourteen days rather than twenty-one.
These are arbitrary decisions of authority, dressed in the language of law. And being arbitrary, they can change—frequently, unpredictably, with retroactive effect in practice if not in theory.
An entrepreneur operating in this system cannot rely on moral intuition. They can rely only on knowledge of the regulations—and awareness that the regulations will change.
Defense as Virtue
Bastiat wrote that the state is the great fiction through which everyone endeavors to live at the expense of everyone else. One may disagree—but it is difficult to deny that the tax system creates a fundamental conflict of interest between citizen and administration.
Defending against excessive fiscalism is not fraud. It is a rational response to a system that is rational only from one side’s perspective.
Tax optimization—legal, deliberate, documented—is not an offense against the common good. It is using the law as the law permits. If the legislator did not intend this, the legislator should have written the regulations differently.
And if the regulations are unclear—and they are always unclear—then an interpretation favorable to the taxpayer is as legitimate as one favorable to the treasury.
Knowledge as Shield
In a world where only death and taxes are certain, knowledge is the only shield.
Knowing what rights you have. Knowing what obligations you bear. Knowing where the boundaries lie—and who draws them. Knowing when to fight and when to yield. Knowing that eight thousand interpretations is not chaos—it is a map of possibilities.
An entrepreneur without this knowledge is like a traveler without a map in a country where the roads change every season. They may be lucky and reach their destination. They may also fall into an abyss they did not see—because no one told them it was there.
What We Do
We represent entrepreneurs across the full spectrum of tax matters: from preliminary inquiries, through audits and tax proceedings, to disputes before administrative courts.
We prepare applications for individual interpretations—because it is better to know the authority’s position before a transaction than after.
We help build structures that are not only efficient but safe—across more than fifty jurisdictions, with full awareness of risks and possibilities.
We defend against security measures and enforcement—because the state should not take before it has proved it has the right to take.
We handle criminal fiscal cases—because the line between optimization and fraud is often a matter of interpretation, and interpretation should not belong solely to the prosecutor.
In Closing
Taxes are certain. Tax law is not.
This is a system that changes faster than you can follow, interpreted by people whose goals differ from yours, enforced by institutions that measure success by the sum of your liabilities.
You can wander this system alone. Or you can have a guide who knows the terrain—because they have spent years learning its topography.
We know this terrain.
