Defending Taxpayers’ Interests 

Proceedings before the tax authorities or administrative courts require the possession of professional knowledge and experience in order to exploit instruments of protection of interests provided for in regulations of law in the most effective way.


Dariusz Malinowski


+48 22 528 11 66




Ewa Szot

Senior Manager

+48 22 528 11 66




Mariusz Jurkiewicz


+48 22 528 11 66



Our Services

Tax rulings and motions for reimbursement of tax overpayment

Within the scope of actions aiming at reducing the tax burden and the risk of tax settlements of taxpayers being challenged by the tax authorities, KPMG in Poland offers professional assistance in the process of obtaining binding tax rulings issued by the Minister of Finance. A favourable ruling is a valuable instrument in building tax optimization safety.


Representation in proceedings aiming at reimbursement of a tax overpayment is also within the scope of the tax advisory services of KPMG. Our professionals can assess the opportunity to recover overpayments of tax, prepare formal motions and provide representation during proceedings.


We offer our support also in the scope of a new instrument of business optimisation, i.e. rulings issued on the ground of the Freedom of Economic Activity Act.


KPMG may assist with:

  • Professional preparation of formal motions,
  • Representation in proceedings,
  • Professional assistance in correctly exploiting the instrument of appeal against an unfavorable standpoint of the tax authorities.


Representing taxpayers in disputes with the tax authorities

As a result of unclear and dynamic tax regulations, even if taxpayers manage to keep current with changes in the law, there is a risk of incompatibility with the requirements of tax law. Such a situation means, that the tax authorities have significant leeway to seek additional income for the State Treasury.
In practice, there are often situations, where unclear tax regulations are construed to a taxpayer’s disadvantage
by the tax authorities.


KPMG offers professional support in helping your enterprise access all the available instruments aiming at defending the interests of the taxpayer in disputes with the tax authorities in wide range of situations.


KPMG may assist with:

  • Representation in tax audits, tax proceedings and customs proceedings,
  • Representation in enforcement proceedings,
  • Representation before the administrative courts,
  • Representation in fiscal penal proceedings,
  • Representation before the civil and penal courts,


Representation before the Court
of Justice of the European Union,
Constitutional Claim and representation in proceedings before the Constitutional Court.


Mitigating the risk of penal and fiscal penal responsibility

Conducting economic activity in Poland is inseparably associated with the risk of penal responsibility. This refers not only to intentional tax fraud, but also to typical mistakes in tax returns, incorrect tax qualification of economic events, omitting to withhold tax due and mistakes in annual financial reporting.


Penal responsibility may be imposed on persons responsible for conducting the economic affairs, e.g. member of the Management Board, finance director, chief accountant.


Potential sanctions falling under of penal regulations include imprisonment, restriction of liberty, fines and entry into the register of convicted persons.


KPMG may assist with:

  • Analysis of potential risks,
  • Recommendations with regard to reducing risk, adjusted to the structure and organization of the client,
  • Preparation of documentation and procedures to reduce the risk of crimes  being committed and to allow lack of guilt to be proved in potential penal proceedings.


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   KPMG w czołówce rankingu

According to the 2013 Tax Companies Ranking compiled by Polish daily “Dziennik Gazeta Prawna”, published on 11th March 2014, KPMG remains a leading Tax advisor.