New legislation on preparation of tax strategy information and its publicizing

The new regulations governing preparation of tax strategy information and its publicizing have not taken effect yet, but they have already raised considerable doubts. The final wording of the Act which introduces the new obligation was promulgated in the Journal of Laws under item 2123. For details of the new legislation, see our tax newsletter: Read

The legislature did not enact any transitional regulations with respect to said obligation. For this reason, there are doubts as to whether the obligation should be fulfilled for the first time for the year:

  •  2020 (by 31 December 2021) or
  •  2021 (by 31 December 2022).

The explanatory memorandum does not answer the questions. They are the more reasonable that during public consultations the need to enact a transitory regulation in this respect was rejected.

We consider it very likely that the obligation will apply to 2020. This view is supported by the fact that the legislator and the Ministry of Finance did not decide to enact any transitory regulations, even though potential doubts had arisen during the public consultations. However, given the doubts, the Ministry of Finance may present a binding opinion and answer the questions posed by taxpayers.

Should you have any questions or doubts as regards the obligation to publish the tax strategy information, you are welcome to contact us.


Michał Wilk Partner, Katowice

T: +48 32 731 68 69
M: +48 500 023 685

Arkadiusz Żurawicki Partner, Warsaw

T: +48 22 690 08 71
M: +48 508 092 989

Szymon Chyra Manager | Tax advisor, Katowice

T: +48 32 731 68 50