NSA ruling: Tax authorities can impose VAT penalty after inspection without separate tax proceedings.

• Taxpayer can be fined in VAT after control
• If taxpayer corrects declaration based on control findings, tax office does not start separate tax proceedings
• NSA ruled that additional VAT liability can be imposed without separate tax proceedings
• NSA agreed with tax office and first instance court that article 165b of tax procedure code does not apply
• VAT penalty is imposed by decision, not as a result of tax proceedings.

Source: podatki.gazetaprawna.pl

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.