On 9 June 2026, the President signed the Act of 29 May 2026 amending the Tax Ordinance and certain other Acts (link to the Act: https://orka.sejm.gov.pl/opinie10.nsf/nazwa/2287_u/$file/2287_u. pdf).
The Act introduces, amongst other things, amendments to the provisions on the reporting of tax arrangements (MDR), which are set out in Section III, Chapter 11a of the Tax Ordinance. The amendments relating to MDR will come into force on 1 October 2026.
The most significant changes concern:
- the removal of the reporting requirement for so-called domestic tax schemes (tax schemes other than cross-border tax schemes);
- the exclusion of value added tax and excise duty from the scope of the MDR provisions;
- the removal of the obligation to have an MDR procedure in place;
- the repeal of the obligation to submit the MDR-2 notification to the Head of the National Revenue Administration;
- the MDR-3 form may be signed by an authorised representative and will be submitted once a year;
- the possibility of issuing individual tax rulings regarding the reporting of tax schemes has been removed.
Recommendations
Given the numerous transitional provisions, every taxpayer who has hitherto been subject to MDR obligations should carry out a detailed analysis of the MDR obligations identified prior to the entry into force of the amending Act. Such taxpayers should also review their internal tax processes.
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