Cooperative Tax Compliance Programme

The Cooperative Tax Compliance Programme is a new form of cooperation between taxpayers and the National Revenue Administration. Taxpayers who decide to join the Programme can expect a number of benefits, but they must be prepared to be open and transparent in tax matters.

Just like other cooperative compliance programmes around the world, the Cooperative Tax Compliance Programme introduced in Poland is based on three principles: mutual trust, understanding and transparency in cooperation with the tax administration.

The main assumption of the Programme is close and continuous cooperation of the National Revenue Administration (the NRA) and the largest taxpayers of corporate income tax.

The Cooperative Tax Compliance Programme is directed at taxpayers with tax revenues exceeding EUR 50 million in a tax year.

Basic information and benefits

Before joining the Programme, it is worth examining whether the taxpayer is prepared to join it, i.e. to verify the status of tax settlements and the correctness as well as completeness of the Tax Control Framework (TCF).

The first step to join the Cooperative Tax Compliance Programme is the submission of an application. After its submission, an initial NRA tax audit takes place, including verification of the correctness of tax settlements and assessment of the implemented TCF.

The audit covers the two preceding tax years and the period of one year until the application for accession to the Programme is submitted. The completion of the NRA audit results in the issuance of recommendations for the taxpayer, and then a cooperation agreement is concluded with the Head of the NRA. The terms of the cooperation agreement and - in particular - the scope of the monitoring audit that will cover the taxpayer, are subject to negotiation.

Below we present selected benefits of joining the Cooperative Tax Compliance Programme. A full and up-to-date list of benefits can be found on the Ministry of Finance’s website:

Certainty and security in the tax area - confirmation of the correctness of fulfilling tax obligations and the maturity of the TCF, as well as the possibility of concluding Tax Agreements with the NRA;
No proceedings under the Fiscal Penal Code for specific years;
Better cash flow as a result of priority processing of tax refunds;
An individual approach and faster contact with the tax administration, which allows for more efficient tax settlements and an increase in their accuracy;

Improving the taxpayer’s image as a socially responsible and transparent entity;
Reducing the obligation to report national tax schemes (MDR);
Possibility of applying a reduced interest rate for late payment (50%) to tax arrears arising as a result of the taxpayer correcting irregularities found during the audit.

Our experience

We have been involved in the development of the Cooperative Tax Compliance Programme from the very beginning - PwC Poland participated in consultations in 2019 regarding the shape and functioning of the Programme as well as took an active part in the work of the Ministry of Finance regarding the TCF assessment model and the enhancement of tax transparency.

Moreover, at the request of the Directorate-General for Supporting Structural Reforms (DG REFORM) of the European Commission, we carried out:

a dedicated training programme for auditors from the Ministry of Finance and the National Revenue Administration;
an Expert Panel, during which, together with external experts, we discussed possible directions of development of the Cooperative Tax Compliance Programme and ways to increase its attractiveness and recognition among taxpayers.

The PwC team supported SIG Sp. z o. o. which was the first taxpayer in Poland to conclude a cooperation agreement with the Head of the NRA and hence joined the Cooperative Compliance Programme. We supported SIG in preparations for accession, as well as in the process of joining the Programme itself (in particular, in submitting the application, going through the tax audit and conducting negotiations of the agreement).

In April 2023, our company won the ranking of one of the most influential newspapers in Poland Rzeczpospolita in the "Commitment to creating good tax law" category for supporting the first taxpayer in the process of joining the Cooperative Tax Compliance Programme and signing the first-ever cooperation agreement. The jury appreciated PwC for comprehensive support in preparations for submitting an application to conclude a cooperation agreement with the Head of the National Revenue Administration and in the process of joining the Programme.

At the invitation of the Ministry of Finance, we have actively participated in the conference entitled: "Tax transparency. Cooperative Tax Compliance Programme - cooperation and better compliance with tax law provisions, which took place on November 29, 2022 at the headquarters of the Ministry of Finance.

Joining the Cooperative Tax Compliance Programme, pioneered by SIG

Learn about the benefits of participating in the Cooperative Tax Compliance Programme, which are noticed by the President and CFO of SIG sp. z o. o. one year after joining. Watch the video.

Find out more about the process of entering the Cooperative Tax Compliance Programme. Get to know the opinions and experiences of SIG representatives who were involved in the project of preparing the company to join the Programme.

Watch the case study

How can we help?

Assessment of readiness to participate in the Cooperative Tax Compliance Programme
Support in implementing recommendations
Support at all stages of joining the Cooperative Tax Compliance Programme
Support of a dedicated Project Manager

Assessment of readiness to participate in the Cooperative Tax Compliance Programme

As part of the analysis of readiness to join the Cooperative Tax Compliance Programme, our experts will assess the efficiency of the implemented Tax Control Framework and the correctness of settlements of taxes (including CIT, VAT, PIT, excise duty, customs duties, etc.). We will provide you with an analysis and recommendations that will allow you to properly prepare to join the Programme.

Support in implementing recommendations

We will help you implement solutions aimed at achieving the desired level of Tax Control Framework maturity and ensuring the correctness of tax settlements. Activities in this area may concern supplementing tax procedures, implementing IT tools, correcting tax settlements, etc.

Support at all stages of joining the Cooperative Tax Compliance Programme

We provide support from submitting the application to signing the Agreement, including during the initial audit and the Independent Audit of the Tax Function.

Support of a dedicated Project Manager

We offer you comprehensive support from an experienced PwC expert who will be responsible for planning and timely completion of tasks related to the Cooperative Tax Compliance Programme. Support includes, in particular, developing a project plan, coordinating team cooperation within the company, and cooperation with NRA advisors and auditors.