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Tax agreements

A tax agreement provides the taxpayer with legal certainty prior to taking action

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

A tax agreement is a tax law instrument dedicated to the participants of the Cooperative Compliance Programme. It allows the taxpayer to submit an application for an opinion on whether a planned action complies with the legal regulations before it is actually undertaken.

The agreement is concluded in writing between the Head of the NRA and a taxpayer who is a party to a cooperation agreement, within the scope covered by that agreement, regarding:

  • the interpretation of tax law regulations;
  • an opinion on top-up taxation;
  • the determination of transfer pricing;
  • the absence of grounds for applying Art. 119a of the Tax Ordinance Act;
  • the amount of corporate income tax liability forecast for the following tax year;
  • any other matter necessary to ensure the proper performance of the cooperation agreement.

The taxpayer may terminate the tax agreement at any time.

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