The case, and more precisely the interpretation of the Director of the National Tax Information in this particular case, raises significant controversy. The “Treasury” stated that the taxpayer should pay tax even on “virtual rewards” that physically do not reach his account.
Surprising tax authority decision
The Polish citizen performed a service for an American company that can be described as “ethical hacking.” It involved the IT specialist searching for security loopholes and then reporting them to his employer. This cooperation lasted from 2018. For discovered security flaws, the Polish citizen received rewards on a “virtual account,” which was part of the service he worked with. For years he did not withdraw the money because he did not meet the formal requirements to do so. This changed in 2025 when he decided to start a business, which opened a gateway for him to withdraw the accumulated funds. That happened. The IT specialist was sure that since the entire amount was paid out in 2025, he would have to pay tax on it when filing in early 2026. To be sure, he requested an individual interpretation from the National Tax Information. To his surprise, the tax authority found that the taxpayer was wrong, and he should pay tax immediately upon receiving each reward, even when the money did not physically reach his account.
The IT specialist must pay tax and… a penalty
That the IT specialist did not receive physical transfers does not mean he should not pay tax on the received reward, even if it is virtual and only appears in the system of the company he worked with – the director of the National Tax Information stated.
The tax authority concluded that receiving money into an account was possible at any time if the taxpayer met all criteria. And fulfilling those criteria would result only from a decision. The requirements mentioned are not only starting a business but also providing a bank account for transfer or submitting a W8-BEN form, which is required by U.S. tax regulations. The “Treasury” stated that this could be done at any time. And receiving a reward – even a virtual one – did not exempt the IT specialist from paying tax.
This means that the unaware IT specialist will now have to bear the consequences of his decisions. Among them is paying overdue tax on each reward. To do so, each bonus received in dollars must be converted to zlotys at the prevailing exchange rate at the time, to determine the tax amount. That is not the end of the matter. The taxpayer will also have to pay interest on the unpaid tax in a timely manner, as well as a penalty for the situation that arose.
The decision of the Director of the National Tax Information in this particular case is controversial because for years the received rewards were not paid out, but when the taxpayer decided to do so, he did not avoid tax liability; he simply wanted to pay tax on the money that he received into his account. Let us remind again that it was in 2025, and the period covered by the remuneration dates back to 2018.
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