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On 11 April 2025, a new revision of the bill amending the VAT Act and amending the act amending the VAT Act and certain other acts was published on the Government Legislation Centre’s website. The key changes brought by the latest revision include the permanent introduction of the “offline24�� mode and the postponement until 31 December 2026 of the abolition of invoices issued using cash registers and NIP-bearing receipts as simplified invoices, the mandatory indication of the KSeF number in payments and the entry into force of sanctions for breaches of KSeF obligations. Furthermore, the bill introduces changes as to the mandatory use of KSeF threshold itself: it will be assessed for 2024 and not, as previously announced, 2025. At the same time, however, the deadline for introduction of the mandatory KSeF remains unchanged, i.e., 1 February 2026 for large taxpayers and 1 April 2026 for other businesses. The Ministry of Finance welcomes comments and remarks on the bill until 25 April 2025. Additionally, on 11 April, the Ministry published an updated schedule of implementing the mandatory KSeF.

On 11 April 2025, two resolutions of the Anti-Tax Avoidance Council, i.e., resolution no. 10/2024 dated 20 December 2024 and resolution no. 1/2025 dated 18 February 2025, were published.

In resolution no.10/2024, the Council assessed a sequence of transactions performed by a family foundation. The Council determined that the transactions resulted in a reduction of the PIT liability, with the tax benefit being gained by excluding from revenue the amount received from the foundation as a loan. Furthermore, the Council stated that the primary aim of the action was to secure a PIT tax benefit, noting that the taxpayer's activities were artificial in nature and that the tax benefit obtained goes against the subject or purpose the provisions of the PIT Act. As a result, the sequence of transactions met the statutory criteria of tax avoidance.

In turn, in resolution 1/2025 the Council assessed the possibilities of applying the GAAR where tax-deductible costs were accounted for in an incorrect manner. According to the Council, in the examined case, tax avoidance cannot be identified, since the taxpayer violated tax law by including depreciation write-offs as tax-deductible costs when they were not eligible for such treatment. This means that the GAAR is not applicable to cases where the taxpayer decreased the amount of tax liability or generated/increase the loss incurred through violation of substantive tax law. Consequently, application of the GAAR in the examined case had no grounds.

On 8 April 2025, a clearance opinion dated 11 March 2025 (case file DKP16.8082.9.2024) on a cross-border merger of companies was published. According to the Head of the National Revenue Administration, the tax consequences of share swapping and cross-border merger take the form of a tax benefit, consisting in exemption from the tax on civil law transactions and CIT-neutrality. However, the Head of NRA noted that this was not the primary or one of the primary purposes behind performing the activity, since the goal of the activities performed is to simplify the structure and to achieve business-justified capital accumulation. Additionally, according to the authority, the activities planned or the benefit to be achieved are not contrary to the subject or purpose of tax law or any of its provisions, nor is the modus operandi employed artificial. Consequently, Article 119a(1) of the Tax Code finds no application in the examined case and the Head of the National Revenue Administration issued a clearance opinion.

On 7 April 2025, the preliminary remarks to the bill amending the act on top-up taxation of members of multinational enterprise groups and large-scale domestic groups (the GloBE Act) were added to the list of legislative work and policies of the Council of Ministers. The bill enacts the EU directive aimed at ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups within the EU, through amendments to the GloBE Act. Among its provisions, the bill addresses the re-recognition of deferred tax liabilities in cases where the related amount remains unpaid, offers clarification on the recognition of deferred tax assets stemming from received credits, and elucidates the requirements for submitting information on top-up taxation as well as the conditions for applying the Accounting Act. The bill is anticipated to be approved by the Council of Ministers in the third quarter of 2025.

On 7 April 2025, the preliminary remarks to two bills amending the Polish Tax Code were added to the list of legislative work and policies of the Council of Ministers. These are the first two bills in a series of the so-called de-regulatory acts. The first bill introduces a general requirement for at least a six-month vacatio legis period for tax bills presented to the Sejm, particularly those that increase the burden on taxpayers and other subjects of tax law. The second bill proposes extending the principle of "in dubio pro tributario" (i.e., resolving doubts in favour of the taxpayer) to situations where there are irresolvable uncertainties regarding the facts of a case. Both bills are anticipated to be approved by the Council of Ministers later in the second quarter of 2025.

On 9 April 2025, the EU agreed to impose retaliatory tariffs targeting almost EUR 22 billion in American products, such as poultry, nuts, fruit, motorcycles and yachts, as a response to tariffs introduced by the US on steel and aluminium imported from the EU. On the same day President Donald Trump declared immediate suspension of the reciprocal tariffs for a period of 90 days and, consequently, decrease of the rates to the level of 10% (against 20% announced). At the same time, the tariff on goods imported to the US from China was increased to 145%. As a result of Trump's announcement, the EU authorities have also put planned activities on hold for a period of 90 days.

This time is to be spent on negotiating the terms of a trade agreement.

On 7 April 2025, preliminary remarks to the bill amending the Act on Counteracting Money Laundering and Terrorist Financing were added to the list of legislative works and policies of the Council of Ministers. The purpose of the bill is to supplement the existing regulations with provisions aimed at counteracting and financing the proliferation of weapons of mass destruction through restrictive measures. Among other things, the bill proposes: broadening the scope of the Act's subject matter, altering the requirements for the individual holding the position of General Inspector of Financial Information, modifying the regulations governing the operation of the Financial Security Committee, introducing administrative penalties, and ensuring the Act's provisions align with those of the EU Directive.

According to the judgment of the Constitutional Tribunal delivered on 8 April 2025 (case file SK 53/21), the provision of the PIT Act, in force as of 31 December 2024 (Article 22(1e)(3)), under which when the object of a non-monetary contribution to a company consists of the taxpayer's own receivables from loan agreements in which the taxpayer acted as the lender, the amount of the loans granted is not deductible for tax purposes, goes against the Constitution. According to the Constitutional Tribunal, the provision resulted in differing treatment between own receivables (which could not be counted as tax-deductible) and purchased receivables (which could be tax-deductible). Additionally, it was imprecise and led to inconsistencies in the jurisprudence of administrative courts.

According to the judgment delivered by the Supreme Administrative Court on 3 April 2025 (case file II FSK 756/23), limits on the possibilities of real property depreciation for real estate companies provided for by Article 15(6) of the CIT Act relate to taxpayers making depreciation write-offs in line with accounting regulations. Conversely, if the taxpayer does not make write-offs in accordance with accounting regulations, the aforementioned limitation cannot be automatically applied. In such cases, the taxpayer may continue using the tax depreciation method initiated after 1 January 2022. In justifying its position, the Supreme Administrative Court emphasized that when introducing the regulation, the legislator did not implement any transitional procedures to suggest that a real estate company could be entirely deprived of the ability to make write-offs from one day to the next.