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The Tax Authority vs. Time: Who Won This Battle?

The Supreme Administrative Court has decided to give the tax authority an early holiday gift: more time to resolve cases.

Resolution III FPS 4/24 determined that the statute of limitations for tax liabilities, in cases of suspension, will only resume after the conclusion of protective proceedings. This means the tax authority can rest easier, while taxpayers… well, not so much.

As our expert, tax advisor, and specialist in tax audits and proceedings at Thedy & Partners, Marcin Bodziony, commented:
“This resolution is undoubtedly a victory for the tax authority. The Supreme Administrative Court had two options. The first assumed that the statute of limitations would continue running after the expiration of a protective decision. The second, which was adopted, means that the clock resumes only after the conclusion of protective proceedings. In practice, this often gives tax authorities more time to settle cases.”

What does this mean for taxpayers? We anticipate that the tax authority will increasingly use tools like protective decisions to safeguard the State Treasury’s interests while also suspending the statute of limitations.

Should taxpayers start practicing patience? Perhaps. But one thing is certain – staying updated on tax law has never been more crucial.

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