As of January 1, 2019, Chapter 11a – Information on tax schemes was added to the Tax Ordinance, which introduced a new institution to the Polish legal system – reporting of MDR tax schemes. The obligation to report the tax schemes applies to three groups of entities, i.e. promoters, beneficiaries and supporters. In practice, this obligation may apply to any natural person, legal entity or organisational unit without legal personality, regardless of the size of these entities. The only limitation is the eligible beneficiary criterion, but it only applies to domestic tax schemes.

Since the reporting obligation for tax schemes concerns a wide range of taxpayers and the regulations in this area are very unclear and complicated, it is difficult to properly implement the MDR obligations.