fiscal offences

Publications - fiscal offences

fiscal offences

Article 77 of the Fiscal Penal Code – the distinction between financial difficulties and a fiscal offence

Article 77 of the Polish Fiscal Penal Code governs situations in which a taxpayer or a tax collector fails to pay the tax collected into the account of the competent tax authority by the due date. The liable person is the individual who in fact manages the entity’s economic matters, particularly finance, even based on […]

fiscal offences

Empty invoices – how not to get caught up in crime

Many Polish taxpayers are convinced that the issue of issuing empty invoices does not concern them at all. They assume that since they do not knowingly participate in such practices, they cannot be held liable for them. Unfortunately, in many cases, they are living under a false sense of security. In practice, it is very […]

fiscal offences

Supreme Administrative Court ‘s signalling decision

On April 14th 2025, the Supreme Administrative Court (NSA) (ref. I FSK 1078/24) issued a verdict in a seven-judge panel, which may significantly change the current practice of tax authorities with regard to the initiation of fiscal penal proceedings. The NSA ruled that the initiation of such proceedings solely for the purpose of suspending the […]

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