The Polish Ministry of Finance published on 20 October 2021, on their website, the latest statistics on the Mandatory Disclosure Rules (MDR).
The statistics represent data related to the submitted MDR forms (MDR-1, MDR-2, MDR-3 and MDR-4) from 1 January 2019 through 30 September 2021 and, in particular, contain information on the number of MDR forms submitted, as well as data regarding the number of delivered Tax Arrangement Number (TAN) confirmation documents in the same period.
The key highlights of the newly published statistics are provided below.
Statistics
Quarterly information about number of “information on tax arrangements” submitted to the Head of National Fiscal Administration:
| Time period | Number of submitted MDR reports | ||
| Initial | Supplementations | Total MDR reports | |
| by 31 March 2019 | 630 | 72 | 702 |
| by 30 June 2019 | 2837 | 208 | 3045 |
| by 30 September 2019 | 5149 | 363 | 5512 |
| by 31 December 2019 | 7075 | 616 | 7691 |
| by 31 March 2020 | 10,548 | 962 | 11,510 |
| by 30 June 2020 | 12,876 | 1,430 | 14,306 |
| by 30 September 2020 | 14,090 | 1,696 | 15,786 |
| by 31 December 2020 | 16,566 | 2,201 | 18,767 |
| by 31 March 2021 | 20,413 | 2,676 | 23,089 |
| by 30 June 2021 | 23,939 | 3,054 | 26,993 |
| by 30 September 2021 | 25,616 | 3,246 | 28,862 |
Quarterly information about number of information on tax arrangements (MDR-1) submitted to the Head of National Fiscal Administration:
| Time period | Number of submitted MDR reports (MDR-1) | |||
| Initial MDR-1 | Incl. cross-border MDR-1 | Supplementations of MDR-1 | Total MDR-1 | |
| by 31 March 2019 | 395 | - | 51 | 446 |
| by 30 June 2019 | 1810 | - | 152 | 1962 |
| by 30 September 2019 | 3213 | - | 233 | 3446 |
| by 31 December 2019 | 4227 | - | 373 | 4600 |
| by 31 March 2020 | 5281 | - | 625 | 5906 |
| by 30 June 2020 | 5751 | - | 939 | 6690 |
| by 30 September 2020 | 6215 | 130 | 1472 | 7364 |
| by 31 December 2020 | 7665 | 1016 | 1600 | 9265 |
| by 31 March 2021 | 8990 | 2166 | 2011 | 11,001 |
| by 30 June 2021 | 9640 | 2443 | 2297 | 11,937 |
| by 30 September 2021 | 10,197 | 2608 | 2465 | 12,662 |
Quarterly information about number of notifications on tax arrangements (MDR-2) submitted to the Head of National Fiscal Administration:
| Time period | Number of submitted MDR reports (MDR-2) | ||
| Initial MDR-2 | Supplementations of MDR-2 | Total MDR-2 | |
| by 31 March 2019 | 152 | 3 | 155 |
| by 30 June 2019 | 482 | 5 | 487 |
| by 30 September 2019 | 774 | 7 | 781 |
| by 31 December 2019 | 1038 | 8 | 1046 |
| by 31 March 2020 | 1245 | 9 | 1254 |
| by 30 June 2020 | 1367 | 9 | 1376 |
| by 30 September 2020 | 1462 | 10 | 1472 |
| by 31 December 2020 | 1680 | 12 | 1692 |
| by 31 March 2021 | 1993 | 14 | 2007 |
| by 30 June 2021 | 2097 | 16 | 2113 |
| by 30 September 2021 | 2174 | 16 | 2190 |
Quarterly information about number of MDR-3 reports (on performing any actions in a tax arrangement in a given reporting period or deriving a tax advantage) submitted to the Head of National Fiscal Administration:
| Time period | Number of submitted MDR reports (MDR-3) | ||
| Initial MDR-3 | Supplementations of MDR-3 | Total MDR-3 | |
| by 31 March 2019 | 83 | 18 | 101 |
| by 30 June 2019 | 312 | 47 | 359 |
| by 30 September 2019 | 670 | 105 | 775 |
| by 31 December 2019 | 1049 | 209 | 1258 |
| by 31 March 2020 | 2898 | 298 | 3196 |
| by 30 June 2020 | 4418 | 436 | 4854 |
| by 30 September 2020 | 4966 | 478 | 5444 |
| by 31 December 2020 | 5609 | 525 | 6134 |
| by 31 March 2021 | 7556 | 581 | 8137 |
| by 30 June 2021 | 9769 | 660 | 10,429 |
| by 30 September 2021 | 10,624 | 680 | 11,304 |
Quarterly information about number of submitted MDR-4 forms (on the marketable tax arrangements made available during the quarter) to the Head of National Fiscal Administration:
| Time period | Number of submitted MDR reports (MDR-4) | ||
| Initial MDR-4 | Supplementations of MDR-4 | Total MDR-4 | |
| by 31 March 2019 | 0 | 0 | 0 |
| by 30 June 2019 | 233 | 4 | 237 |
| by 30 September 2019 | 492 | 18 | 510 |
| by 31 December 2019 | 761 | 26 | 787 |
| by 31 March 2020 | 1124 | 30 | 1154 |
| by 30 June 2020 | 1340 | 46 | 1386 |
| by 30 September 2020 | 1447 | 59 | 1506 |
| by 31 December 2020 | 1612 | 64 | 1676 |
| by 31 March 2021 | 1874 | 70 | 1944 |
| by 30 June 2021 | 2433 | 81 | 2514 |
| by 30 September 2021 | 2621 | 85 | 2706 |
Quarterly information about number of delivered TAN confirmation documents since 1 January 2019:
| Time period | Valid tax arrangement numbers (TAN) | Including cross-border (since 01.07.2020) | Invalid TANs | Number of delivered TAN confirmation documents |
| by 31 March 2019 | 100 | - | 0 | 100 |
| by 30 June 2019 | 265 | - | 0 | 265 |
| by 30 September 2019 | 381 | - | 0 | 381 |
| by 31 December 2019 | 897 | - | 0 | 891 |
| by 31 March 2020 | 1010 | - | 0 | 1010 |
| by 30 June 2020 | 1322 | - | 301 | 1623 |
| by 30 September 2020 | 2216 | 77 | 301 | 2517 |
| by 31 December 2020 | 3895 | 373 | 301 | 4196 |
| by 31 March 2021 | 5659 | 1508 | 301 | 5960 |
| by 30 June 2021 | 6666 | 1798 | 301 | 6967 |
| by 30 September 2021 | 7363 | 1937 | 303 | 7666 |
EY Doradztwo Podatkowe Krupa SP. K., Warsaw
- Andrzej Broda
- Kateryna Simonova
Ernst & Young LLP (United States), Polish Tax Desk, New York
- Sylwia Migdal
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