Although the Mandatory Disclosure Rules (MDR) have been in force in the Polish legal system for several years, their application in practice raises numerous doubts and is the subject of disputes between taxpayers and tax authorities. At the same time, failure to comply with the MDR rules may result in the imposition of high penalties and fines, and sometimes also criminal and fiscal liability. The increased tax risk associated with the obligation to report certain transactions/structures under the MDR regulations is also not insignificant.
Our advice on reporting tax schemes includes, among others:
Analysis of the obligation to report a particular transaction / arrangement under the MDR provisions;
Support in complying with formal and reporting obligations related to MDR;
Drafting internal procedures to counteract non-compliance with the obligation to provide information on tax schemes under Article 86l of the Tax Ordinance.