As of 1 January 2019, there are provisions that impose on certain entities an obligation to provide information on the so-called “Tax schemes” (MDR, Mandatory Disclosure Rules). The tax scheme is defined very broadly and the conditions for recognizing a given arrangement as a tax scheme often raise a number of doubts.
Failure to comply with the obligations related to providing information on tax schemes, failure to report information on the tax scheme to the Head of the National Revenue Administration, providing this information after the deadline or reporting errors may result in penal and fiscal liability of management board members and high fines.