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Changes to tax limitation periods and fiscal penalties

The act introduces new rules for tax liability limitation periods, including for undisclosed income. It also changes fiscal penalty regulations – even after a tax debt expires, the perpetrator may be obliged to pay its monetary equivalent.
Key points
The limitation period for establishing tax liability on undisclosed income is 5 years from the end of the calendar year following the year the tax obligation arose.
Suspension of limitation during forced mortgage or tax lien – the period resumes only after property seizure or lien removal.
One-year extension of limitation period when correcting declarations that reduce tax or increase refunds – further extension possible for repeated corrections.
Obligation to pay the monetary equivalent of the evaded public law liability in case of its limitation – applies to specific situations in the Fiscal Penal Code.
The limitation period for the punishability of fiscal offenses, if proceedings are initiated, is 5 years (for offenses under Art. 44 § 1 item 1) or 10 years (for offenses under Art. 44 § 1 item 2) from the end of the basic period.
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55%
VOTING RESULTS
2026-03-13
For 193
Against 238
Abstain 0
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Status:
Vetoed
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Additional Information
Rządowy projekt ustawy o zmianie ustawy - Ordynacja podatkowa oraz ustawy - Kodeks karny skarbowy.
Print number: PROJEKT USTAWY 2288
Process start date: 2026-02-26
Voting date: 2026-03-13
Voting no: 84