Taxpayers are assigned to their competent tax authorities. The principle is to be assigned to a territorially competent authority.
However, there are a number of exceptions to this rule. One of them concerns the existence of “specialized” authorities for larger (due to the level of income) or otherwise “specific” taxpayers (e.g. banks).
Within this model, there are authorities competent for voivodeships (from one to three in the region), as well as – called the “super-office” – the Head of the First Mazovian Tax Office, which is supposed to group the “elite” of taxpayers.
The Ministry of Finance has presented a draft decree changing the rules for qualifying taxpayers to be serviced by the First Mazovian Tax Office (Pol. PMUS). This change is therefore important for the indicated large companies that have so far been covered by central service in Warsaw.
New income threshold of €100 million
Currently, entities with annual revenues exceeding EUR 50 million are eligible for services by PMUS.
The bill provides for raising this threshold to EUR 100 million, which means that some taxpayers – despite their previous qualification – may be excluded from the central service.
The new regulations are to enter into force on 1 January 2026, with the exception of enforcement regulations, which will take effect 14 days after publication.
Transition period for companies with revenues of €50-100 million
However, for companies with revenues of €50-100 million, there is a transitional provision that allows them to retain jurisdiction by PMUS if:
- generated revenues between EUR 50 and 100 million in one of the two indicated tax years (after 2021, with the last one ending after 2023) and
- do not submit a resignation statement until October 15, 2025.
Failure to meet the conditions or resignation
Taxpayers who do not meet the above conditions or decide to resign from the service provided by PMUS will be automatically redirected to the locally competent tax office at the beginning of 2026.
