Mandatory Disclosure Rules

As of January 1, 2019, Chapter 11a - Information on tax schemes was added to the Tax Ordinance, which introduced a new institution to the Polish legal system - reporting of MDR tax schemes. The obligation to report the tax schemes applies to three groups of entities,...

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  • tax review to verify the reporting obligations of the tax schemes
  • one-day audit to identify the tax schemes
  • analysis of a single activity, event in terms of MDR duty (identification of the promoter, beneficiary, supporters and their duties)
  • preparation or verification of an internal procedure for preventing a failure to comply with the obligation to provide information on the tax schemes
  • developing instructions for the recognition and reporting of tax schemes
  • support in filling in and sending MDR forms, including MDR – 3 to the Head of the Cash Fund
  • conducting training courses and workshops to prepare the taxpayer’s employees for independent performance of their duties in the field of tax schemes
  • permanent tax support service for MDRs (guarantee of response within 2 working days at most)
  • preparation of a defence file – preparation of a document justifying why a given event/activity was not considered as a tax scheme
  • Supporting the taxpayer during tax and customs-treasury controls in the implementation of MDR obligations
  • Periodic monitoring of compliance with the implemented reporting policy
  • analysis of the reported tax schemes to assess whether the schemes require MDR-3 reporting

Breaking news


Ministerstwo Finansów


Questions and answers

Since when should tax schemes be reported?

The regulations concerning reporting of tax schemes were introduced into the Polish legal system on 1 January 2019.  Therefore, as a rule, the MDR provisions apply to tax schemes for which one of the events resulting in the obligation to provide information occurred...

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Paweł Rosiński

MDR practice leader

Tax advisor. A graduate of the Jagiellonian University in Cracow and Maria Curie-Skłodowska University in Lublin. Practicing tax law. Specializes in income taxes, real estate tax and reporting of tax schemes.

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