Poland’s tax administration is relying less frequently on traditional inspections and increasingly verifying businesses’ tax settlements using data from the Standard Audit File for Tax system (JPK) and the National e-Invoicing System (KSeF). According to a report by MDDP and the Lewiatan Confederation, tax authorities carried out nearly 2.3 million verification activities in 2025, opening an average of 19 new procedures per minute. These checks uncovered almost PLN 11 billion in tax arrears, more than 25% higher than a year earlier.
“We are seeing a change in the nature of the relationship between tax authorities and taxpayers. The way tax settlements are verified is changing. In previous years, verification was much more often conducted through standard customs and tax inspections. Recently, however, it has increasingly taken the simplified and more taxpayer-friendly form of verification activities,” Tomasz Michalik, partner and tax adviser at MDDP, told Newseria.
Data from the second edition of the report, Entrepreneurs Under the Tax Authority’s Microscope, prepared by MDDP and the Lewiatan Confederation, show that more than 12.4 million verification activities were conducted between 2021 and 2025. Of these, 10.6 million concerned VAT, personal income tax, corporate income tax and excise duty. The procedures uncovered PLN 38.8 billion in tax arrears, including more than PLN 37 billion related to VAT, PIT, CIT and excise duty. According to the report’s authors, verification activities generate better results for the state budget than tax and customs-and-tax inspections combined.
Since 2022, the number of verification activities conducted each year has been steadily increasing. Nearly 2.3 million were carried out in 2025 alone, up 10% on the previous year and 23% more than in 2022. The exception was 2021, when the number of such procedures exceeded 2.4 million.
“A verification activity is a procedure in which tax authorities review certain elements of a taxpayer’s settlement and may ask clarifying questions to determine whether it is correct. In general, they either issue recommendations or prepare a report on the verification activity, based on which the company corrects its return, or, if no irregularities are found, the procedure simply ends without further consequences,” explains Przemysław Pruszyński, Director of the Tax Department at the Lewiatan Confederation.
Verification activities are simpler and less formalised than traditional audits. They allow authorities to quickly and extensively review selected areas of tax settlements and are not subject to the same procedural restrictions imposed by tax regulations. Of great importance is also the authorities’ expanding access to data and analytical tools, which make it possible to verify settlements remotely, often without the need for prior contact with the taxpayer.
“The tax administration knows more about taxpayers. Businesses submit an increasing amount of information, ranging from JPK_VAT files to this year’s new development, the National e-Invoicing System. The administration can now see virtually complete taxpayer settlements, so it no longer needs to conduct on-site inspections. Instead, it can remotely verify whether a company’s tax settlements are correct,” Pruszyński says.
In 2021, the average amount identified per verification activity was PLN 1,705. By 2025, it had risen to PLN 4,681, despite a similar number of procedures. This may indicate that tax authorities are becoming more effective at selecting entities for review and making better use of available analytical tools.
“The tax authorities are now much better than before at using the information they have been able to collect through the Standard Audit File and other channels. They also appear to be capable of efficiently analysing the sources from which these data are obtained. As a result, verification activities are targeted at specific taxpayers, specific actions and areas for which the authorities are already prepared. This makes the process efficient, streamlined and effective,” the MDDP tax adviser says.
More formalised instruments, such as JPK, KSeF, DAC7 and STIR, mean that businesses are now operating under what may amount to continuous 24/7 monitoring. When tax authorities contact a given company, they often already possess most of the information they need.
“This could result in almost permanent surveillance of taxpayers, because nearly all information will be available to tax authorities either in real time or close to real time. We are on the verge of a major change in both the authorities’ inspection capabilities and, most likely, the way inspections themselves are conducted,” Michalik argues.
A survey conducted for the report found that 91.3% of respondents had encountered verification activities during the past five years. Entrepreneurs generally assess this form of contact with the tax authorities positively. Nearly half of respondents, 47.1%, rated it good or very good, while 15.4% rated it poor or very poor.
“A verification activity is simple, straightforward and relatively convenient for both sides. However, it does not guarantee taxpayers the same rights, and for that reason it can unfortunately be abused,” the MDDP tax adviser says.
Businesses surveyed for the report expect greater predictability in the procedure. Formal notification of its completion was supported by 89.5% of respondents, while 87.5% said they would like to receive a document setting out the outcome and findings. In addition, 85.5% pointed to the need for a defined maximum duration of such activities.
As the report’s authors stress, these answers should be interpreted as a request for a basic standard of information rather than a demand for excessive formalisation. Without confirmation that a case has been closed and without clarity on the result, verification activities remain opaque from the taxpayer’s perspective. The duration and repeatability of such procedures are equally important. Survey respondents do not challenge the flexibility of the process or ongoing contact with officials by email and telephone, but they argue that such interactions cannot continue indefinitely.
At the same time, taxpayers want appropriate limits to be maintained. They do not want verification activities to evolve into full tax audits. According to the report, 61.5% of respondents oppose expanding the tax authorities’ evidentiary powers, while 72.1% do not support allowing witnesses and parties to be questioned or inspections to be carried out as part of the procedure.
“Generally speaking, the tax system is becoming increasingly complicated. We have more and more issues, interpretations and disputes between taxpayers and the tax administration, with widely differing outcomes. This makes operating a business increasingly demanding,” says the Lewiatan Confederation expert.
The fundamental expectation of entrepreneurs is that the number of changes to tax law should be reduced. When changes are introduced, businesses expect a longer vacatio legis period so that they can prepare for new obligations.
In the 2025 International Tax Competitiveness Index, prepared by the US think tank Tax Foundation, Poland was placed near the bottom of the ranking. The country ranked 35th out of 38 OECD members, compared with 31st place a year earlier. This means that Poland’s tax system is considered less competitive than those of most developed economies.
“Constant changes are the most difficult challenge for entrepreneurs, because they require continuous implementation, preparation, additional costs and compliance with tax obligations. Then, once a business has done all that and is ready to operate under the new rules, another change appears in the following year, followed by yet another one,” Pruszyński says.
Experts discussed relations between businesses and tax authorities during the Lewiatan Confederation’s Tax Council Congress, held in Warsaw on 16 June.
