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State of epidemic emergency to be called off in Poland


Maria Wośkowiak

15 May 2023 

According to a draft regulation recently published by the Ministry of Health, an epidemic emergency for SARS-CoV-2 infections is going to be called off across Poland on 1 July 2023. The state of epidemic emergency was introduced in Poland in May 2022 and replaced the state of epidemic that had been in force since March 2020. 

A number of special legal and tax measures have been introduced under the special COVID Act during the epidemic and the state of epidemic emergency. Some of them ceased to be in force in May last year after the state of epidemic was called off. Others will cease to apply on the day the state of epidemic emergency is called off or shortly after that date. 

Key implications of the end to the state of epidemic emergency: 

  • Taxpayers will be required to have up-to-date certificates of residence.
  • Tax arrangements other than cross-border arrangements (so-called domestic arrangements) will have to be reported again.
  • Taxpayers will have seven days instead of 14 days for reporting a payment to a non-whitelisted account.
  • The waiting time for an advance tax ruling will again be three months.
  • The postponement fee for deferral of due date of tax or tax arrears or on payment of the tax or tax arrears in instalments will be charged again.
  • The transfer pricing preferences in the form of: the exemption from the obligation to hold the associated enterprise's statement about making an adjustment, and the exclusion of the condition that the associated enterprise cannot make a loss to be exempt from the obligation to prepare a local file for transactions between associated enterprises – if the entity's turnover decreased by at least 50% compared to the previous year will cease to apply.
  • The preferences can be applied either until the state of epidemic emergency is called off or for the tax year in which the state of epidemic emergency was in force.
  • Contractual penalties and damages paid for: defects in delivered goods, work and services performed and for delay in delivery of defect-free goods or delay in the removal of defects in delivered goods or work and services performed, will not be tax-deductible. 

If you have questions about the discontinuation of the state of epidemic emergency in Poland, you are welcome to contact us. 


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Dominika Tyczka-Szyda

Tax adviser (Poland)


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