Tax settlement agreement – a revolution in tax disputes from 2028
What you will learn from this article:
- What is the planned tax settlement agreement?
- Who will be able to use it and under what conditions?
- What benefits can it bring to taxpayers?
- When will the new regulations come into force?
Tax settlement agreement
A new institution in tax law, or what is a tax settlement agreement?
The draft law of April 24, 2026, introduces a completely new solution to the Polish tax system – a tax settlement agreement. Its main goal is to reduce the number and duration of tax disputes by preventing them from arising and enabling an early, amicable resolution of the conflict between the taxpayer and the tax authority.
A tax settlement agreement is an alternative dispute resolution (ADR) solution. It will provide an additional, optional option to resolve a case or avoid a dispute. The taxpayer or payer will initiate the settlement, while the tax authority will have the discretion to accept it.
Importantly, the settlement is intended to definitively close the matter of the liability covered by it, provided that the taxpayer complies with the conditions agreed with the tax authority.
Tax settlement agreement
Who will be able to benefit from the tax settlement?
The new solution will be available to taxpayers and payers, including:
- entrepreneurs,
- natural persons not conducting business activity,
- taxpayers, in the scope of taxes not related to business activities.
A tax settlement may be concluded in the case of tax proceedings concerning liabilities worth at least the minimum wage.
This arrangement will be available exclusively to taxpayers who demonstrate a constructive attitude toward tax authorities and a realistic ability to repay their arrears. Individuals previously convicted of tax offenses, suspected of aggressive tax optimization, or those who have failed to respect previous settlement agreements will not benefit from the arrangement.
Tax settlement agreement
What are the most important benefits of a tax settlement?
The project provides a wide range of benefits for taxpayers:
Tax settlement agreement
What is not negotiable?
A tax settlement will determine the correct tax amount. However, this amount will be determined in accordance with applicable regulations. Negotiations may also concern the method and terms of repayment of arrears.
What's more:
- the settlement does not violate the principle of universal taxation,
- its conclusion must be fiscally beneficial for the State Treasury.
What will the procedure look like?
Settlement proceedings:
- will be informal and amicable,
- may include consultation meetings,
- will not be limited by a rigid deadline.
The tax authority will retain full powers as in ordinary proceedings and will be able to refuse to conclude the settlement at any time.
After signing it:
- the taxpayer will not be able to submit further corrections to the declaration,
- the tax authorities will not initiate any audits or proceedings in this matter.
Tax settlement agreement
Foreign inspirations and entry into force date
The project draws inspiration from solutions used in other EU countries, especially from the long-standing practice of the Netherlands. The planned effective date of the regulations is 1 January 2028. The tax settlement is intended to become an important tool supporting entrepreneurs and taxpayers in Poland. The tax settlement will not introduce new obligations; it will only provide additional rights to taxpayers.
Tax settlement agreement
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