Important changes in tax and customs inspections from 1 October 2025 – more flexibility for taxpayers.

Monika Bilska

On 1 October 2025, amendments to the National Revenue Administration Act and the VAT Act will come into force, which may significantly affect the course of tax and customs audits. The amendment aims to streamline and clarify the provisions that have been causing interpretative doubts and practical difficulties for taxpayers for years.

What will change?

The new regulations provide, among other things, for:

• the possibility of submitting an ‘initial’ tax return within 14 days of delivery of the authorisation for the audit or delivery of its results – which was previously strongly questioned,
• the option of partial acceptance of the audit findings – taxpayers will be able to agree only with some of the findings and settle their accounts in this respect, limiting the dispute to the contentious issues only,
• the possibility of applying a preferential rate of additional VAT liability (up to 15%) also in the case of filing a ‘primary’ return.

What does this mean for taxpayers?

The changes introduced are a step towards greater transparency and balance in the taxpayer-authority relationship. Thanks to them:

• the risk of a dispute with the tax authority will be reduced,
• the audit may be completed faster, without the need for a full tax proceeding,
• companies will gain tools to respond faster and limit the financial consequences of any irregularities.

This is a good time to review the procedures in place in companies and prepare for the practical application of the new regulations.

More details and a practical analysis of the changes are available on our VAT Blog: https://sendero.pl/wazne-zmiany-w-kontroli-podatkowej-i-celno-skarbowej-od-1-pazdziernika-2025-r