Mere negligence does not entitle officials to instrumentally apply VAT sanctions. The taxpayer’s action must consciously aim at tax fraud and depletion of budgetary liabilities. This was confirmed by the Provincial Administrative Court in Białystok. However, the abuse of this form of punishment is a frequent operation of the tax office. This is confirmed by lawyers, and the Court of Justice of the EU is also on the side of Polish companies.
Source Prawo.pl