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Tax Controversy Services in Poland (Audits, Proceedings & Litigation)

What are a tax audit and tax proceedings?

A Polish tax audit (including a customs and fiscal audit) is designed to verify the accuracy of a taxpayer’s settlements and to confirm whether the tax reported in the return is correct. During an audit or tax proceedings, the Polish tax authorities may review transactions and source documents, request explanations, interview witnesses, or carry out inspections-often creating operational pressure and uncertainty for management. Grant Thornton supports clients in Poland throughout the process, helping them respond consistently, protect their rights, and manage tax risk.

  • Who can benefit from support during a tax audit or tax proceedings?

    Our support during a Polish tax audit, customs and fiscal audit, or tax proceedings is addressed to any taxpayer who needs professional advice and hands-on assistance in dealings with the tax authorities in Poland. We advise small, mid-sized and large companies. We act as your authorised representative, so you can keep day-to-day operations running while we manage the process and communication.

  • When should you involve a tax advisor?

    If your business has been notified of an audit or tax proceedings, you should engage a tax advisor as early as possible-ideally from day one. Initial actions (including how and when you provide documents and explanations) can materially affect the scope, duration, and outcome of the case. That said, we can also step in at a later stage and help you regain control of the process.

  • Key benefits of professional support

    We help you build an effective defence strategy tailored to your facts and evidence, explain complex Polish tax rules in practical terms, and recommend the best course of action. You gain confidence that the audit is conducted within the legal framework and that your procedural rights are protected-reducing the risk of adverse findings driven by misunderstandings or incomplete submissions.

Tax auditors have arrived? Key reminders

  • Do not waive your right to participate in the audit-you may appoint an authorised representative to attend on your behalf.
  • Appoint one point of contact for the auditors-this does not have to be an employee; it can be a Grant Thornton tax advisor acting as your representative.
  • Do not give up participation in witness interviews-your representative may attend and safeguard procedural rights.
  • Request that questions and document requests be provided in writing.
  • Verify whether requests made by the auditors remain within the scope defined in the authorisation and notice.
  • Remember you can negotiate deadlines for providing explanations or documents.
  • You may object to an unlawful extension of the audit.
  • You have the right to submit explanations during the audit and after receiving the audit report.

Scope of our support in Poland

Our support in all types of proceedings before the Polish tax authorities and administrative courts includes, in particular:

  • Audit strategy and case roadmap

    Together with you, we develop the most effective strategy for a Polish tax audit, customs and fiscal audit, or tax proceedings-covering key arguments, evidence, timelines, and a clear communication plan.

  • Ongoing support during verification activities

    We represent you as an authorised representative during a tax audit, customs and fiscal audit, or tax proceedings, and we handle cases before the Polish tax authorities at both instances.

  • Support in cases of withheld VAT refunds

    If your VAT refund in Poland has been withheld or the refund deadline has been extended, our actions can help clarify the case faster and, in many situations, support the release of the VAT refund. We prepare tailored submissions and explanations, coordinate evidence, and engage directly with the competent Polish tax office to resolve questions efficiently and secure the refund due.

  • Recovery of overpaid taxes (tax overpayment refunds)

    If you face issues obtaining a tax overpayment refund, our support may accelerate the review and increase the likelihood of a positive outcome of the overpayment claim. We draft the required filings and liaise with the relevant Polish tax authorities to help you recover the tax as quickly as possible.

  • Explanations, objections, appeals and procedural filings

    We draft complaints to the Regional Administrative Courts and represent taxpayers before those courts. We also prepare cassation complaints to the Supreme Administrative Court and act as counsel in proceedings before the Supreme Administrative Court.

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How we work: engagement process

Support from a tax advisor can be provided-and is often crucial-at any stage of a case conducted by the Polish tax authorities.
  • Start of the case:

    Early-stage support helps you stay in control of the authorities’ actions and the quality and consistency of information and documents submitted. In many situations, effective handling at this stage can prevent escalation to further stages of audit or dispute.

  • During the audit/proceedings:

    Ongoing support helps ensure the case is conducted in line with your business interests and within procedural rules, while reducing the disruption and administrative burden on your organisation.

  • Closing stage:

    Once the case is concluded, where permitted under the regulations, we prepare objections to the audit report and/or an appeal against an adverse decision.

Early-stage support helps you stay in control of the authorities’ actions and the quality and consistency of information and documents submitted. In many situations, effective handling at this stage can prevent escalation to further stages of audit or dispute.

Our tax advisors can represent you at every stage before the tax authorities and, subsequently, before the administrative courts in Poland. We know that a well-designed strategy and disciplined execution are critical to protecting the taxpayer’s position and achieving a successful outcome.

Depending on your needs, we provide end-to-end support in an ongoing audit or tax proceedings (including representation in subsequent instances and before administrative courts), or we support you with drafting and optimising filings during the case. Close cooperation ensures a coherent, evidence-driven approach and consistent messaging to the authorities.

Why Grant Thornton?

Proven experience in tax disputes and proceedings

With years of hands-on experience and strong knowledge of market practice, Grant Thornton advisors effectively support clients in Poland in achieving favourable outcomes in complex tax disputes-often at the earliest possible stage. At every step, we aim to secure the best result for the client while providing a clear, realistic assessment of prospects in the dispute with the tax authorities.

In Poland, we support clients in audits and proceedings concerning corporate income tax (CIT), personal income tax (PIT), value added tax (VAT), excise duty, civil law transactions tax (PCC), local taxes and customs duties. We also assist in cases related to tax refunds (including VAT refunds)-covering verification activities and challenging unjustified extensions of VAT refund deadlines.

  • 30+ years

    in Poland

  • 1200+

    employees in 7 offices

  • 2500+

    clients

Tax Controversy Services in Poland – FAQ

What documents are typically requested during a Polish tax audit?

Usually accounting ledgers, VAT registers/JPK files, invoices, contracts, transfer pricing documentation (if applicable), bank statements, and evidence supporting the business purpose of transactions. We help you prepare a complete, consistent evidence pack.

Can I communicate with the tax authority through an authorised representative?

Yes. You may appoint a representative to handle correspondence, attend meetings, and provide explanations. This often reduces disruption and helps ensure responses are technically correct and aligned with the case strategy.

Why do VAT refunds in Poland get delayed or withheld?

Most often due to verification of supply chains, invoice reliability, due diligence, or questions about the substance of transactions. We support you with explanations, evidence, and procedural steps aimed at releasing the refund.

What happens after the audit ends – do I always receive a decision?

Not always. A tax audit typically ends with an audit report; the authority may then initiate tax proceedings that can result in a formal decision. We advise on objections to the report and next procedural steps.

How far back can the Polish tax authorities review transactions?

The review period depends on the tax type and limitation rules, but authorities commonly analyse several prior years. We assess limitation periods, scope, and risks, and help you respond proportionately to the requests received.

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Tax Controversy Services in Poland (Audits, Proceedings & Litigation)

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