Follow-up: Mass Penalties and Sealing of Premises – 2026 the Businesses Have Strong Legal Grounds for Protection
by admin
In my last post, I shared my observations on the aggressive enforcement activity at the end of 2025. Today, at the beginning of the new year, I would like to provide several “weapons” to strengthen the legal protection of Bulgarian businesses against administrative arbitrariness. Do not hesitate to object if you disagree with an Acts...
December 2025: Mass Penalties and Sealing of Premises – Enhanced Collection or Administrative Arbitrariness?
I have never been a fan of end-of-year retrospectives. But today, on the last day of 2025, I feel obliged to share an experience I am witnessing for the first time in my practice of over 20 years. I will remember the end of this year for the extremely aggressive control activity by the revenue...
Two CJEU Rulings on the Joint and Several Liability of a Manager for a Company’s VAT Obligations
In the first half of 2025, the Court of Justice of the European Union (CJEU) issued two rulings on Polish cases that provide guidance on the conditions under which the joint and several liability of a manager for a company’s VAT obligations may be engaged. Background Case C-277/24 (M.B. – Adjak) of 27 February 2025...
Employers beware! ECJ Case C-442/22 – employer’s VAT liability for employee’s fraud
Background The Polish tax authorities found that, between January 2010 and April 2014, Company P had issued 1 679 invoices for the sale of fuel in a petrol station without paying the corresponding VAT to the state budget. It appeared that all of these invoices were falsely issued by the employee P.K. with no consent or knowledge...
