Tax audit in Poland: organising evidence and responses to the authority

Reviewed: 13 October 2026 · Polish law and taxation

Preparing for a Polish tax audit starts with identifying the authority's request, the procedure being used and the period under review. Document collection should follow that analysis. Sending a large, unindexed folder may make the evidence harder to understand and expose inconsistencies that the business has not yet investigated. The objective is a reliable account supported by traceable records.

Identify the procedure and control the timetable

Verification activities, a tax audit, a customs and fiscal audit, and tax proceedings are distinct Polish procedures. Their deadlines and taxpayer rights cannot be treated as interchangeable. Check the opening document, the authority, the scope of authorisation, the service date and the instructions provided. If a representative is involved, confirm the authority granted and the correct arrangements for receiving correspondence.

Create a single register of requests and deadlines. Record receipt, the information requested, the responsible employee, the internal review date and evidence of submission. If documents cannot be assembled within the available time, assess the appropriate route for requesting additional time promptly. Sending a request does not itself establish that a deadline has been extended.

Organise the file around the underlying transaction

For each transaction, connect the contract, order, invoice, payment and evidence of actual performance. Service evidence may include reports, correspondence, work products and acceptance records. For goods, transport and warehouse records may be relevant. The file should explain what happened, when, who participated and how the event was reflected in the tax treatment.

Preserve originals and version history. Use clearly named working copies without altering source documents. Where records disagree, establish the reason with the people who handled the transaction before drafting an explanation. Distinguish verified facts from assumptions. If a document is missing, describe that position accurately and identify any alternative reliable evidence rather than creating retrospective material that appears contemporaneous.

Make the response easy to follow

An effective response addresses the authority's questions in order, states the relevant facts and identifies the supporting annexes. An invoice alone may not explain the commercial substance of a service. Equally, unrelated material should not be added simply to increase the size of the submission. The disclosure obligation must be assessed under the relevant procedure, including applicable legally protected confidentiality.

Before submission, compare the response with accounting records, earlier explanations and the annexes themselves. Appoint one person to approve the final version. Retain an exact record of what was provided, to whom, when and through which channel. This reduces the risk of different departments sending inconsistent descriptions of the same event.

Illustrative example and the audit report

The authority asks about marketing services. Accounting holds the invoices, while evidence of delivery is kept by sales and the external agency. The business links orders to campaign reports and payments, explaining how the documents connect. It does not manufacture earlier acceptance records. This is a hypothetical example rather than a client case study.

When a Polish tax audit report is served, compare its findings with the evidence. Article 291 of the Tax Ordinance provides 14 days from service for objections or explanations, accompanied by appropriate evidence requests. This rule concerns that particular tax audit report. It should not be applied to every document issued in other audit or tax procedures.

Fourteen days: calculate the deadline and identify the document

For a deadline expressed in days, exclude the service date. If the last day falls on a Saturday or public holiday, apply Article 12 of the Tax Ordinance and check any exception. Objections to an audit report under Article 291 are not an appeal against a tax decision. Identify the disputed findings, evidence and evidentiary requests. Set internal approval before the statutory deadline, leaving time for signature and confirmation of proper filing.

Checklist and next steps

• Confirm the procedure, scope, service arrangements and representation.
• Establish a deadline register and evidence index.
• Verify facts with the people responsible for the transactions.
• Review the response and annexes together.
• Keep submission evidence and plan the review of findings.

Start by organising the authority's correspondence and the records for the relevant period. Discuss the audit with TLP and review the tax audits and disputes service.