The obligation imposed by the Ministry of Finance, apart from the advisors themselves, also applies to taxpayers. Even if the tax scheme is implemented without the participation of an advisor. Unfortunately, the scope of the obligation is broad and unclear. It may turn out that taxpayers, completely unconsciously, implement a scheme which is subject to reporting.
Caution is advised here, as the fine for failure to comply with the obligation may amount to as much as PLN 21 600 000
Reporting should be part of the policy of due diligence in the context of collective liability regulations, therefore each entity should carry out at least an initial verification in this respect.