Introduction

The functioning of a society would not be possible without proper management. The socio-economic sphere must beregulated in a certain rule-bound manner. In this context, it is particularly important on the part of national authorities to introduce appropriate tax planning and management of public finances. The principles on the basis of which tax regulations are constructed should be optimal enough to take into account not only fiscal needs, but also a number of other objectives [Sosnowski, 2012]. “The imposition of taxes by the state is to guarantee the implementation of certain functions that the tax fulfills” [Szlęzak-Matusewicz, 2008, p. 17, own translation]; this is primarily the fiscal function (providing funds to the state budget), although also other functions of tax must be borne in mindsuch as the regulatory function (redistribution of funds) or the stimulation function (influencing the decisions of taxpayers through tax structures) [ Jaszczyński, 2017]. Moreover, taxes should be shaped in such a way that they do not constitute an excessive fiscal burden that could lead to tax evasion.

The basis of financial management, as well as the duty of public authorities is to collect revenue [Chojna-Duch, Litwinczuk, 2009]. Taxes make up the fiscal system, which should be managed in a specific way, because tax collection is associated with interference in the material sphere of taxpayers, and thus cannot be based on discretionary regulations. The Act of 27 August 2009 – Public Finance, [ Journal of Laws – Dz.U. 2021, item 305, hereinafter: the Public Finance Act] contains basic principles to be followed by public authorities in collecting public revenue. It should also be noted that public revenue consists, among others, of public levies, among which taxes are ranked first. It is not a coincidence that taxes were indicated in the first place, since, for example, in 2020, they accounted for about 88% of state revenues [Sprawozdanie z wykonania budżetu państwa za okres od 1 stycznia do 31 grudnia 2020]. Therefore, taxes that play a special role and dominate the structure of the state revenues, and thus have a significant impact on the socio-economic sphere, should be shapedon the basis of certain legal principles.