Poland’s constitutional court has agreed with the National Council of Tax Advisors that mandatory disclosure rules (MDR) implementing the EU Directive 2018/822 (DAC6) in 2019 are unconstitutional, because they violate tax advisors’ legal professional privilege.

The rules require service providers to notify beneficiaries and other obligated parties of tax planning arrangements.
The judgment goes against that of the Court of Justice of the European Union (CJEU) in July 2024’s Case C-623/22