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Between declaration and implementation – aplication of the principle of in dubio pro tributario in the interpretative and the jurisprudence of tax authorities and administrative courts

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The principle of in dubio pro tributario aims to safeguard taxpayers’ rights but faces interpretative challenges.
Over the past decade, courts showed a restrictive judicial approach to the concept of interpretative doubts.
Article 2a of the Polish Tax Ordinance provides context for the principle's application in tax law.
Selected case law illustrates the principle’s effectiveness and suggests necessary legal recommendations.

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Analysis reveals interpretative challenges in applying in dubio pro tributario by tax authorities and courts.

Monika Wyszomirska (2025) studied this question.

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