Data publikacji: 6/23/2026
Data aktualizacji: 6/23/2026
According to OECD publications[1], for a cooperative compliance-type programme to be effective, it must be tailored to the needs, capabilities, and expectations of both the administration and taxpayers in a given country. Therefore, the essence of implementing a cooperative compliance programme is its adaptation to the socio-economic context of the respective country.
Consequently, in order to verify the proper adaptation of the cooperative compliance programme implemented in Poland to the Polish legal system and socio-economic conditions, the Ministry of Finance determined that it was necessary to conduct a pilot of the Cooperative Compliance Programme along with its evaluation.
The pilot was initially scheduled to last for three years under the provisions implementing the Programme, and was subsequently extended to five years. Furthermore, the transitional provisions allowed for the possibility of limiting the number of entities participating in the Programme to twenty.
Given the necessity to have the Programme's pilot evaluated by a professional and independent entity, the Ministry of Finance submitted a request to the European Commission (EC) to select such an entity and to finance the evaluation under the Technical Support Instrument. This request was approved. Consequently, commissioned by the EC, the evaluation of the Cooperative Compliance Programme pilot was conducted by Kozminski University (ALK) as part of the project titled "Development of the cooperative compliance programme implemented in Poland". Within the framework of this project, qualitative and quantitative research was carried out among taxpayers and other Programme stakeholders between 2021 and 2023. Based on the conducted research, Kozminski University provided an objective assessment of the functioning of the Cooperative Compliance Programme, identifying its strengths and weaknesses, as well as areas requiring improvement.
Following the evaluation of the Cooperative Compliance Programme pilot, Kozminski University prepared a final report in 2024, which was published on the website of the European CommissionEuropean Commission’s website.
The results of the Programme's evaluation were also presented and discussed during a conference organised at Kozminski University in February 2024.[2]
The areas identified as requiring improvement included, among others, the need to:
In response to taxpayers' expectations arising from the evaluation, significant changes to the application process for the Cooperative Compliance Programme were introduced in 2024. Conceptual work on these improvements was conducted in cooperation with businesses as part of tax consultations.
As a result of these consultations, to facilitate companies' entry into the Programme, an ITCF maturity assessment model was developed. This model, based on a five-level maturity scale, provides enterprises with a tool to conduct an objective self-assessment of the quality of their ITCF. This enables businesses to better understand how to develop their tax procedures and manage tax risks more effectively. The model not only indicates a specific path for the ITCF's development, but also ensures the transparency of the assessment principles by specifying the minimum quality requirements that must be met by Programme participants.
Furthermore, Guidelines and best practices regarding the ITCF have also been developed. This document contains practical tips and examples of how businesses can effectively implement appropriate processes, procedures, and tools for managing the tax function.
During the evaluation, expanding the Programme to include capital groups was identified as a key condition for the Programme's further development. Currently, the Programme is aimed solely at the largest taxpayers, who can enter into a cooperation agreement on an exclusively individual basis. Consequently, even if a group comprises several entities with revenues exceeding EUR 50 million, they do not have the option to submit a joint application to conclude an agreement. Therefore, economic entities belonging to capital groups, despite following a common tax strategy and a uniform tax function management system, can participate in the Programme exclusively on an individual basis.
Hence, increasing the accessibility of the Cooperative Compliance Programme and tailoring it to the needs of businesses, including those operating within capital groups, is the main challenge currently faced by the Ministry of Finance.
[1]https://www.kozminski.edu.pl/pl/pierwsze-doswiadczenia-oraz-perspektywy-programu-wspoldzialania
[2]Co-operative Tax Compliance: Building Better Tax Control Frameworks, OECD Publishing, Paris,Informacje w języku angielskim na stronie OECD
We ensure that tax audits are conducted in a reliable, transparent, and collaborative manner. Therefore, from 1 January 2026, we are introducing a tax audit quality assessment system.
Our objective is to ensure the high quality of tax audits through uniform rules for their monitoring, assessment, and continuous improvement. We strive for the audit to be a process based on dialogue, mutual understanding, and the ongoing resolution of emerging issues.
During the audit, we pay attention to factors such as the commitment of the audit team, the timeliness of the activities carried out, and the manner of communication. An essential element of the assessment is also the feedback from the audited entities, collected in the form of satisfaction surveys.
Any comments or suggestions concerning the course or quality of the audit may be submitted at any time during the audit to the dedicated email address:ocena.jakosci.audytu@mf.gov.pl
The feedback provided is important to us, as it helps to improve the way audits are conducted and to build partnerships based on trust.
Pursuant to Art. 20u of the Act – Tax Ordinance, a taxpayer who has entered into a cooperation agreement is required, among other things, to maintain an effective and adequate Internal Tax Control Framework (ITCF).
The quality of the ITCF is verified, inter alia, as part of the Independent Tax Function Audit (NAFP) periodically commissioned by the taxpayer.
Please be advised that the assessment of the effectiveness and adequacy of the ITCF within the NAFP should be conducted using the ITCF maturity assessment model published on the website of the Cooperative Compliance Programme.
According to this model, the ITCF is considered effective and adequate starting from level 3 ('defined').
The ITCF maturity assessment model is available at:
/pozostale/program-wspoldzialania-pw/ramy-wewnetrznego-nadzoru-podatkowego-rwnp/
Why is this important?
The method of conducting this ITCF assessment is crucial to the quality and utility of the audit results. The application of a uniform ITCF maturity assessment model ensures the comparability and transparency of the assessment results and mitigates the risk of divergent interpretations.
In practice, this means that an ITCF assessment based on the model is not only an element of reporting within the NAFP, but also a management tool: it allows for the structuring of conclusions, the prioritisation of improvements, and the monitoring of progress in subsequent audit cycles.