During the approval process of the Act on the Registration of Sales, the parliamentary committee added a significant increase in sanctions and fines for breaches of tax obligations to the draft legislation. As of the new year, new penalty limits apply for failure to fulfil basic tax obligations under the Tax Code.
These conditions apply only if specific tax laws do not provide for a separately determined penalty for the relevant type of tax. The new penalties for breaches will be imposed starting from 1 January 2026.
- Overview of Changes in Penalties
The minimum penalty for violations of the Tax Code is set at EUR 100.
| Reason for penalty | Minimum until 31 Dec 2025 | Minimum from 1 Jan 2026 | Maximum until 31 Dec 2025 | Maximum from 1 Jan 2026 |
| Failure to file a tax return within the statutory deadline | EUR 30 | EUR 100 | EUR 16,000 | EUR 30,000 |
| Failure to file a tax return after a request from the tax authority | EUR 60 | EUR 100 | EUR 32,000 | EUR 60,000 |
| Failure to meet registration obligations within the statutory deadline | EUR 60 | EUR 100 | EUR 20,000 | EUR 30,000 |
| Failure to meet notification obligations within the statutory deadline | EUR 30 | EUR 100 | EUR 3,000 | EUR 10,000 |
| Failure to fulfil an obligation imposed by a decision of the tax authority | EUR 30 | EUR 100 | EUR 3,000 | EUR 10,000 |
| Failure to fulfil a non-monetary obligation under the Tax Code or a special regulation | EUR 30 | EUR 100 | EUR 3,000 | EUR 10,000 |
The tax authority remains obliged, when determining the amount of the penalty, to take into account the seriousness, duration, and consequences of the unlawful situation, as well as the tax reliability index.
- Reduction of the Penalty
The amendment also introduces a reduction of the penalty in the form of a “discount” if the taxpayer pays the penalty within 15 days of the delivery of the decision issued in the assessment proceedings. In such a case, the tax office or customs office will reduce the penalty by one third, meaning that the taxpayer will be required to pay two thirds of the imposed penalty.
The deadline for filing an appeal against a decision imposing a penalty remains unchanged. An appeal may still be filed within 30 days from the delivery of the decision determining the amount of the penalty.
