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Changes to tax limitation periods and fiscal penalties

The act introduces shorter limitation periods for tax liabilities related to undisclosed income sources. It also changes the rules for limitation of fiscal offenses and introduces new financial obligations for offenders when public law claims become time-barred.
Key points
Reduction of limitation period to 5 years for liabilities from undisclosed income sources.
Extension of limitation period by one year when tax declarations are corrected to reduce tax or increase refunds.
Suspension of limitation period upon registration of compulsory mortgage or fiscal pledge.
New obligation to pay monetary equivalent of depleted public law claims when they become time-barred.
Changed rules for calculating limitation periods for fiscal offenses – from end of year of payment deadline.
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55%
VOTING RESULTS
2026-03-13
For 193
Against 238
Abstain 0
Full voting results open_in_new
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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