Is there a place for Mandatory Disclosure Rules (MDR) intheir current form within a rational tax system?

<ns3:p>The article discusses the implementation of Council Directive (EU) 2018/822 of May 25, 2018 (DAC6) into the Polishlegal system, analyzing the compliance of the introduced regulations with the principles of a rational taxsystem. The author highlights the issue of gold-plating EU provisions, which has led to extending reporting obligationsto domestic tax schemes and various types of taxes, thereby exceeding the directive’s minimum requirements.This practice results in disproportionate administrative burdens for taxpayers and tax advisors, while simultaneouslyundermining trust in the tax system. The article emphasizes that the lack of clear definitions for keyterms, such as “tax scheme” or “main benefit test,” significantly complicates their application and leads to legaluncertainty. Ambiguities in the regulations cause taxpayers to frequently report arrangements that have no realconnection to aggressive tax planning but merely stem from lawful use of tax preferences. Consequently, thisleads to an unnecessary increase in the number of reported tax schemes, hindering the fulfillment of the primaryobjective of the tax scheme reporting mechanism.</ns3:p>