Tax Office Scrutiny of Bank Transfers - Limits and Penalties

Tax Office scrutiny of bank transfers - what you need to know

Since July 2022, the National Revenue Administration (Krajowa Administracja Skarbowa) has had extended powers to monitor the personal finances of citizens. This means that the tax authorities can review the history of your bank accounts and analyse incoming and outgoing transfers, and can even do so without first informing the account holder. These rules were introduced to tighten the tax system and counter the grey economy.

The main legal act governing banks' obligations to monitor transactions is the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (the AML Act). Under it, financial institutions must monitor the legality of the operations carried out by their clients and report any suspicious transactions to the relevant state authorities.

Importantly, scrutiny does not concern only large business transfers. Ordinary transfers from a personal account - for example, a cash gift to a family member or payment for a car bought from a private individual - may also attract the authorities' interest. That is why it is so important for every citizen to know the applicable limits and the consequences of failing to account for a transaction to the tax authorities.

Which transfers are monitored and reported to the tax authorities?

Banks do not report every transfer, but they are required to report transactions that meet certain criteria. The Inspector General for Financial Information (GIIF) receives information from financial institutions about transactions that may indicate money laundering, terrorist financing or other breaches of tax law. Based on the data collected, the GIIF decides whether a case should go to the Polish Tax Office (urząd skarbowy) or directly to the public prosecutor.

The categories of transactions of particular interest to law enforcement and the tax administration include:

• Transfers of large amounts - especially one-off transactions exceeding the reporting threshold.
• Frequent transfers of smaller sums - made at short intervals that add up to a high total value (so-called structuring, i.e. splitting transactions).
• Transfers from many senders of similar amounts - which may indicate unregistered activity or an unlawful source of funding.
• Transfers with suspicious payment references - e.g. unclear or vague references, or ones suggesting fictitious legal grounds.
• Unusual foreign transfers - especially from high-risk countries designated by the FATF.

It is worth stressing that a single transfer of yours appearing in the monitoring system does not mean an automatic tax audit. The authorities analyse transactions comprehensively, looking for patterns and irregularities that may point to the concealment of sources of income or the commission of a fiscal offence.

How much money can you transfer without scrutiny? Thresholds in 2025 and 2026

Many Poles ask themselves: what amount can I transfer without risking the tax authorities' attention? The answer is not clear-cut, because the rules do not set a fixed limit below which a transfer is completely "invisible" to the supervisory authorities. There are, however, thresholds above which banks must report transactions automatically.

The EUR 15,000 threshold - reporting obligation

Under the AML Act, banks are required to report to the GIIF above-threshold transactions, i.e. those whose value exceeds the equivalent of EUR 15,000. At a euro exchange rate of around PLN 4.24 (as at mid-2026), this comes to roughly PLN 63,600. Every transfer exceeding this sum is automatically registered and may be subject to analysis.

Lower limits applied by banks

In practice, many financial institutions apply internal limits lower than the statutory threshold - for example EUR 10,000 (approx. PLN 42,000). This means that even a transfer below the official reporting threshold may be recorded and reported if the bank considers it suspicious. The compliance policies of individual banks differ, so the EUR 15,000 threshold should not be treated as an absolute safety limit.

If you are making a transfer that constitutes a cash gift, remember the separate obligations arising from the Inheritance and Gift Tax Act. Gifts between the closest family members (the so-called zero group) may benefit from a tax exemption, but only if they are reported on form SD-Z2 within 6 months of receiving the funds and the bank transfer is documented.

Penalties for concealing income - legal and financial consequences

The consequences of failing to account for a transaction to the Tax Office can be very severe. The tax authorities are entitled to verify whether your expenditure is consistent with your declared income. If you own a luxury car or apartment, or fund expensive travel, while your tax return shows low income, this discrepancy is grounds for initiating an audit.

The most important consequences for a person whose unreported income is discovered are as follows:

• A 75% penalty tax rate - undisclosed sources of income are taxed at as much as 75% of the value of the unreported income. This is one of the highest rates in the Polish tax system.
• An obligation to pay the outstanding tax with interest - even if the authority does not apply the penalty rate, the taxpayer must pay the tax due together with late payment interest, which accrues from the date the liability falls due.
• A prison sentence of up to 5 years - in extreme cases, where the concealment of income is classified as a fiscal offence involving a significant amount, the court may impose a custodial sentence.
• Blocking of the bank account - the GIIF or the public prosecutor may order the temporary suspension of transactions and the freezing of the account, making it impossible to use the funds held in it.

Particularly importantly, the tax authorities may analyse archived documents going back up to 5 years. This means that a transfer made several years ago, which did not arouse suspicion at the time, may be challenged in later audit proceedings. The statute of limitations on tax liabilities does not protect you where the tax authorities can show that income was deliberately concealed.

How to protect yourself? Practical tips and legal help

The best protection against the negative consequences of a tax audit is diligently documenting all transactions and settling your tax liabilities on time. Here are some practical tips to help you avoid problems with the tax authorities:

• Always enter a precise transfer reference - avoid vague descriptions. State the exact reason for the transaction, e.g. "gift from mother", "payment for car - agreement of ...".
• Document the sources of larger amounts - keep contracts, proofs of sale, gift deeds and other documents confirming the legality of the funds.
• Report gifts on time - if you receive a gift from a member of your closest family, file form SD-Z2 within 6 months to benefit from the tax exemption.
• Do not split large transfers into smaller ones - so-called structuring is itself treated as suspicious behaviour and may result in proceedings being initiated.
• Consult a lawyer for larger transactions - a specialist's help will allow you to classify the transaction correctly and avoid costly mistakes.

Tax law and anti-money laundering regulations are complex and change dynamically. Interpreting the rules yourself may lead to an unintentional breach of the law, the consequences of which can be very serious - from financial penalties running into thousands to criminal liability.

Are you planning a large transaction, have you received a summons from the Tax Office, or do you want to make sure your transfers are properly accounted for? Contact our firm. Our experienced lawyers specialising in tax and financial law will help you protect your interests, prepare the necessary documentation and represent you effectively before the tax authorities. Do not wait for an audit - take care of your financial security today.