In its judgment of September 17, 2025, the Supreme Administrative Court (NSA) overturned the unfavorable judgment of the Provincial Administrative Court (WSA) in Rzeszów in the case concerning VAT settlements.
Our Firm joined the proceeding at the stage of preparing a cassation appeal to the Supreme Administrative Court. The allegations raised in our cassation appeal were found to be valid by the Supreme Administrative Court. The Supreme Administrative Court agreed with us that the court of first instance had incorrectly assessed the issue of the instrumental initiation of proceedings in a tax offense case and the resulting effect in the form of suspension of the limitation period for tax liabilities.
The case was handled by Agnieszka Soja, Partner at SPCG, who heads the tax law and fiscal penal proceedings practice at SPCG.
