Silent Consent of the Tax Office: When Lack of Response Can Have Consequences

Which regulations have already been announced, what remains a draft, and when silence from the office does not imply consent.

Status checked: November 2, 2026. We are not a law firm. This guide is for informational and educational purposes; it is not individual legal or tax advice. Regulations and drafts may change. Before making decisions regarding your business, check the current text of the law and consult the matter with the appropriate specialist.

Legal Status and Main Principles

Silent resolution means that under conditions specified by law, the lack of a decision from the authority within a specified time frame results in a legally prescribed effect. It is not a general principle that every letter without a response implies the office's consent. The type of case, completeness of the application, deadline, and any actions taken by the authority are significant.

Important distinction: The Act of June 11, 2026, on simplifying administrative procedures, Journal of Laws 2026, item 875, provides that from January 1, 2027, there will be a solution concerning certain applications for the cancellation of small debts under the conditions specified in the law. A broader draft UD436 aims to introduce general frameworks for silent resolution of matters in the Tax Ordinance. These are separate acts and different stages of work. The law published in the Journal of Laws; draft UD436.

The proposed broader solution covers only matters specified in the regulations, not all taxes and applications. Do not equate debt cancellation with deferral of payment or installment arrangements. Before calculating the deadline, check the relevant regulation, the date of receipt of the complete application, the prerequisites, and whether the office has performed any action excluding silent resolution.

What to do: keep confirmation of submission and receipt, check the category of the case, and monitor correspondence. If you need a document confirming the effects of the decision, check the possibility of obtaining a certificate. Do not assume in advance that a lack of response after two months has canceled the debt.

First, Check the Basis of Your Application

Not every tax matter is subject to silent resolution. The mere fact of sending a letter, the passage of time, or a phone call with an official is not sufficient to assume that the application has been accepted. Check the specific regulation applicable to the case, the type of debt, statutory prerequisites, and transitional provisions.

Cancellation is Not Installments

Cancellation means giving up the pursuit of the debt to the extent specified in the decision; deferral and installment arrangements change the payment conditions. An entrepreneur should not transfer the procedure of one relief to another. The limit resulting from the minimum wage also requires verification according to the law applicable to the specific application.

Practical Example

A company wants to apply for relief due to a small debt. Before assuming that the application can be resolved silently, it should determine the type of debt, the amount, the appropriate office, and the date of application of the relevant regulation. Then, it should monitor the correspondence from the authority. In other matters, such as those concerning installment arrangements, do not automatically apply the same rule.

It is advisable to keep a copy of the application, supplementary documents, and official confirmation of delivery. If the authority requests supplementation, pay attention to the content of the request and its impact on the course of the proceedings. When silent resolution may be significant for a bank or contractor, check the possibility of obtaining a certificate.

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