On 1 January 2019 new regulations introducing the reporting obligation under the Mandatory Disclosure Rules introduced  into the Polish tax system came into force. The new provisions raise many questions and, contrary to the initial statements of the Ministry of Finance, the new law have very far-reaching implications for “ordinary” taxpayers.

Also the scope of the Polish MDR legislation extends beyond the scope of the DAC-6 Directive. The Polish statute includes a longer list of hallmarks and even the lack of a tax advantage does not rule out a tax reportable arrangement.
Even after 2 years of this legislation, we have much more experience, but still many questions remain unanswered.
Practice has shown that the regulations are often incomprehensible to taxpayers. Most troublesome is understanding what a tax scheme actually is and what roles the respective participants play in the reporting process.

1. The most important differences between Polish MDR regulations and DAC-6 Directive;
2. Tax reportable arrangements vs. GAAR;
3. Who is obliged to report?
4. Other specific hallmarks – typical Polish rules;
5. Transactions subject to reporting based on so far practice;
6. How to ensure tax security of the company – MDR policy and process;
7. Sanctions / Penalties;
8. What is important from the perspective of international groups?