Supreme Administrative Court: Administrative penalties may be imposed after the limitation period has expired
Not only failure to submit explanations, but also insufficient submission thereof may be punishable by an administrative penalty. A taxpayer who believes that the penalty has been imposed after the expiry of the limitation period may possibly not pay it and defend their views in separate proceedings. This is confirmed by a recent judgment of the Supreme Administrative Court. Commentary by Kamil Szczęsny, lawyer, court representative of the company concerned can be read in today's article at Prawo.pl: https://www.prawo.pl/podatki/kary-porzadkowe-po-uplywie-terminu-przedawnienia-zobowiazania,496979.html
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