podatki.gov.pl - Benefits of joining the Cooperative Compliance Programme

Benefits of joining the Cooperative Compliance Programme

See what you can gain by joining the Cooperative Compliance Programme

Data publikacji: 6/25/2026
Data aktualizacji: 6/25/2026

Certainty in the application of tax law

  • You can be certain that your company's current activities comply with the applicable tax law
  • You can consult the National Revenue Administration (NRA) audit team on significant business decisions on an ongoing basis before making them;
  • You can conclude a tax agreement on important issues, including the interpretation
    of regulations, transfer pricing, tax avoidance, or the amount of advance tax payments
    (Art. 20zb of the Act - Tax Ordinance);
  • Fees related to the conclusion of the agreement are either reduced by half compared to standard protective instruments (such as an APA, a GloBE opinion) or are not charged at all (Art. 20zc of the Act - Tax Ordinance); furthermore, any potential fees are collected only after the agreement is concluded

Tailored service

  • You have direct contact with an NRA auditor who knows the specific nature of your business and will assist you in tax matters

No sanctions

  • You benefit from a waiver of fiscal penal sanctions pursuant to Art. 20zm of the Tax Ordinance Act

No or reduced interest

  • Adjustments to tax settlements during the cooperation period do not result in the calculation of default interest (Art. 20zm, sec. 1, point 2 of the Tax Ordinance Act)
  • You can also benefit from a 50% reduction in interest even before signing the cooperation agreement (Art. 20zm, sec. 1, point 1 of the Tax Ordinance Act)

Faster tax refunds

  • Your applications are processed as a priority, which also means a shorter waiting time for a tax refund

Exemption from the minimum tax

  • You do not pay the minimum income tax (Art. 24ca, sec. 14, point 11 of the CIT Act)

Exemption from SENT notification

  • You are not required to notify specific transports to the SENT system if you meet the conditions set out in Art. 5 or Art. 6 of the Act of 9 March 2017 and transport goods from CN chapters 61, 62, 64 or CN code 6309 00 00; the exemption applies from 17 March 2026

More effective tax management

  • You structure your processes and implement best practices, which allows for:
    • better resource utilisation
    • greater accuracy of settlements
    • strengthening the role of taxes within the organisation

Risk-adjusted supervision

  • The Head of the NRA adjusts the form and frequency of supervision to your company's risk level (Art. 20v, point 1 of the Tax Ordinance Act)
  • The NRA cannot conduct a tax audit in your organisation, and a customs and fiscal audit may only be conducted by the Head of the NRA (Art. 20v, point 2 of the Tax Ordinance Act); the so-called cross-check requires the consent of the Head of the NRA (Art. 20v, point 3 of the Tax Ordinance Act)

Improved tax reputation

  • You gain the image of a reliable contractor who conscientiously fulfils their tax obligations, which builds trust among clients, suppliers, and business partners
  • You have easier access to financing, as banks and financial institutions are more willing
    to grant loans and credit to companies with a positive tax reputation and low tax risk
  • You ensure an increase in the company's value, as investors perceive companies with
    a positive tax reputation as more stable and better managed

Exemption from domestic MDR

  • You are not required to report domestic tax arrangements (MDR), in accordance with
    Art. 86a, sec. 5, point 2 of the Tax Ordinance Act
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