Extension of VAT liability timescale; refund changes; easier refunds
Poland is working on an amendment to various tax laws, most notably the Tax Ordinance and the VAT Act. The objective of the proposed reform is to simplify and clarify existing regulations, aiming to improve both taxpayer compliance and administrative efficiency. If approved, the new legislation is scheduled to come into effect on 1st January, 2026.
Polish KSeF e-invoicing begins rollout 1 February 2026. See our Poland VAT guide for more details.
2026 VAT-Related Changes:
Limitation Period Adjustment:
The amendment introduces a mechanism allowing the extension of the standard five-year limitation period for tax liabilities by an additional 12 months. This extension would apply when a taxpayer submits a correction to a tax return within the final 12 months before the expiration of the limitation period. This would give tax authorities additional time to verify the correction and issue an appropriate decision.
Streamlined Overpayment Refunds:
To reduce bureaucracy, the revised rules will eliminate the need for taxpayers to file a separate application for overpayment refunds when the overpayment arises from a corrected VAT declaration—responding to previous concerns over excessive formality.
Clarified Input Tax Refund Rules:
The amendment provides clearer guidelines on how tax authorities may determine the correct value of VAT refunds or input tax to be carried forward in cases where irregularities are found. This applies particularly when a taxpayer only reports input tax (e.g., on purchases) but no output tax in a given period.
MDR (Mandatory Disclosure Rules) Simplification:
Notably, the new rules will require businesses to report the use of tax schemes (MDR-3) only once a year, rather than on an ongoing basis. Moreover, the obligation to maintain an internal compliance procedure for MDR reporting will be abolished.
Standardized Deadline Rules:
The proposal also standardizes how tax-related deadlines are calculated, ensuring that when a deadline falls on a Saturday or public holiday, the rules clearly allow the next working day to be used for compliance.
Reforms with KSeF e-invoicing mandate
In parallel with this legislative overhaul, Poland has introduced measures such as the National e-Invoicing System (KSeF), now mandatory for certain entities, and digital reporting enhancements to improve VAT transparency. These changes indicate a broader trend toward tax digitization and real-time compliance enforcement.
