Areas of Strength

• Poland performs relatively well in tax collection and recovery. Tax arrears remain below the EU average, having decreased in recent years. This suggests strengthened recovery mechanisms and more effective enforcement actions, including due to increasing reliance on digital tools.
• The tax administration is making progress in the digital transformation. Over the past years, increasing efforts have been made to further digitalise the tax administration, including specific measures within the Recovery and Resilience Plan (RRP) to foster the roll-out of e-services. The use of big data analytics and cross-checking tools contributes to strengthening risk-based audits and reduces opportunities for fraud, ultimately improving tax collection efficiency.

Areas for Improvement

• There is scope to improve the monitoring of compliance gaps. While the Polish tax administration publishes VAT gap estimates on an annual basis, currently national estimates of other tax gaps are not available. However, Poland takes part in a number of initiatives at EU level, such as the EU FISCALIS programme on tax gap estimation, and is making use of the Technical Support Instrument to advance its tax gap estimation capabilities. The size of the shadow economy is estimated to be above the EU average, and the latest available estimates from the Polish Economic Institute (2022) point to a corporate income tax (CIT) gap of 30%.
• The VAT compliance gap is high and increasing. At 16% of the VAT Total Tax Liability (VTTL), Poland has the EU’s third largest VAT compliance gap. Several factors are likely to have contributed to the most recent increase in VAT non-compliance, including a rise in bankruptcy declarations, an increase in the share of services in the economy, and growing consumption of recreational services, restaurants, and accommodation.
• Poland could enhance fiscal transparency and accountability by systematically reporting on –and evaluating– tax expenditures. The last detailed report identified tax expenditures worth 5.6% of GDP in 2018, and indicators point to high tax complexity. There would be benefit in establishing a transparent and systematic framework for tax expenditure reporting and evaluation, including regular publication of expenditure data and independent audits. The OECD Economy Survey for Poland 2025 suggests that Poland should carry out comprehensive spending reviews and introduce tax expenditure reviews.

Tax Complexity

Poland ranks last among the 27 Member States in the Tax Complexity Index (‘TCI’) where a higher rank corresponds to lower tax complexity. The TCI is based on the Global MNC Tax Complexity Project, a joint research project of Deborah Schanz (LMU Munich) and Caren Sureth-Sloane (Paderborn University). The TCI 2024 places Poland 23^rd among the Member States with regards to Tax Framework Complexity, and 26^th with regards to Tax Code Complexity. This suggests that multinationals face a rather complex CIT system in Poland, both in terms of the tax processes carried out by the tax authorities (notably in the area of enactment, according to the authors), and of the structure of the tax regulations (particularly in the area of dividends, according to the authors).

The full Commission Staff Working Document of the Mind the Gap Report - Challenges and opportunities for tax compliance and tax expenditure in the EU regarding Poland can be found here.

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