Mandatory Disclosure Rules (MDR) are one of the most difficult tax issues that a taxpayer has to deal with. This is due to the fact that the analysis of individual events in terms of the reporting to the Head of the National Revenue Administration (KAS) requires extensive experience and cross-sectional knowledge of taxes and principles of international tax planning. Identifying reportable events requires not only knowledge but also co-operation within the organisation. Furthermore, completing the formalities themselves involves in-depth analysis of regulations, explanatory notes and knowledge of the report forms. In spite of these difficulties, penal sanctions of up to PLN 30 million can be imposed for non-compliance with the obligations provided for in the Fiscal Penal Code.


Our experts will assist you in the following areas:


  • providing MDR training to finance departments and anyone else who should have knowledge of the MDR issues
  • developing internal (mandatory and optional) procedures covering the MDR identification and reporting, including an analysis of the possible recognition of an entity as a promoter
  • conducting reviews to verify whether the taxpayer has correctly and completely identified the arrangements to be reported to the National Revenue Administration and has correctly complied with the related obligations
  • assisting in determining the scope of reporting and related disclosure obligations, the role in specific MDR as well as in identifying other participants and the deadlines for complying with any legally required obligations
  • assisting in completing the forms and drafting the necessary notifications as well as in any contacts with the National Revenue Administration, etc.