Poland’s Ministry of Finance has proposed amendments to the mandatory disclosure rules (MDR) for potentially aggressive tax arrangements on 17 February 2025.
The draft law aims to improve relations between taxpayers and tax authorities and increase their efficiency.
Poland’s MDR rules follow EU Directive 2018/822 (DAC6) but also require reporting of domestic arrangements. The amendments propose exempting legal counsel, attorneys, tax advisers, and patent attorneys from reporting obligations and limiting their role in informing clients of their DAC6 reporting duties.
DAC6 promotes transparency and fairness in taxation. It applies to cross-border tax arrangements involving multiple EU or non-EU countries with specific characteristics (hallmarks). These arrangements must be reported if they fall within scope, even if they comply with national law.
The government is expected to adopt these amendments by Q2 2025.
