Mandatory Disclosure Rules Simplified: Domestic Tax Schemes No Longer Reportable
From October 1, 2026, Poland simplified its mandatory disclosure regime (MDR) by eliminating the obligation to report domestic tax arrangements. Only cross-border tax schemes now require reporting, reducing paperwork and penalties for taxpayers and advisors.
On October 1, 2026, Poland's revised mandatory disclosure rules (MDR — raportowanie schematów podatkowych) took effect, streamlining what must be reported to the Polish tax authority. Under a law signed by the President on May 29, 2026, the obligation to disclose domestic tax schemes was abolished; only cross-border tax arrangements now require formal reporting.
What Counts as Reporting Now
Taxpayers and tax advisors must still file mandatory disclosure forms for transnational tax schemes—arrangements that involve entities or operations in multiple countries or affect international tax obligations. Purely domestic structures, planning, and arrangements are no longer subject to the MDR filing requirement.
Why This Matters
The change reduces bureaucratic burden on individuals and small-to-medium enterprises that use standard domestic holding structures, family business arrangements, or intercompany financing. It also aligns Poland with EU best practices by focusing MDR on genuinely cross-border risks.
Practical Changes
- Scope narrowed: MDR forms are required only for transnational schemes
- Domestic planning exempt: No reporting needed for wholly Polish corporate structures, family foundations, or intercompany transactions within Poland
- Advisor liability reduced: Tax advisors designing domestic strategies no longer face penalties for failing to disclose client arrangements
- Record-keeping unchanged: Taxpayers must still retain documentation; the reporting obligation simply disappeared
What This Means for Expat Business Owners
If you operate a domestic sole proprietorship (JDG) or hold Polish company shares purely for Polish operations, you will see no change—you were already exempt. However, if you hold a Polish company as part of a multinational structure, employ transfer-pricing strategies, or operate across EU borders, verify with your tax advisor whether your arrangement qualifies as cross-border under the new narrower definition. Failure to disclose a reportable transnational scheme can still result in penalties; the change only eliminates domestic schemes from the requirement. Review any restructuring plans with a Poland tax advisor to confirm compliance.
Sources
Independent app, not a government. General information, not advice. The official source:
