Current Report No. 24/2025
With reference to the current report No. 24/2023 of 20 June 2023 on the ruling of the Provincial Administrative Court in Gliwice, issued on the same day, in which the aforenamed court revoked in its entirety the decision, appealed by ZM SILESIA, of the Head of the Fiscal Administration Chamber in Katowice of 26 October 2022 (nr 2401-IOV1.4103.76.2022.IK), and the preceding decision of the Head of the Małopolska Customs and Fiscal Office in Kraków of 24 September 2020 (nr 358000-CKK3-2.4103.1.2020.25) on the tax on goods and services for the period between January 2013 and December 2014, determining the outstanding VAT liability of the subsidiary, i.e. ZM SILESIA S.A. (“ZM SILESIA”) for 2013 – 2014 in the amount of PLN 97.3 million plus interest, as well as subsequent reports, including information in the last periodic report of the Issuer which advised of the cassation complaints to the Supreme Administrative Court (“SAC”) filed by the parties, the Management Board of Boryszew S.A. (“Company”, “Issuer”) advises that on 9 October 2025 it became aware of the SAC ruling issued on the same day, in which the court dismissed the cassation appeal of the Head of the Fiscal Administration Chamber in Katowice and the cassation appeal of ZM SILESIA, holding that the statute of limitations on all tax liabilities sought under the proceedings in question had expired. The SAC upheld the position of the PSC, questioned the correctness and effectiveness of the tax authorities’ efforts to possibly suspend or interrupt the course of the disputed tax liabilities. The above judgment finally ends the tax dispute.
Also the Management Board of Boryszew S.A., with reference to the current report No. 20/2024 of 26 June 2024 on the ruling issued the same day by the Provincial Administrative Court in Krakow (I SA/Kr 216/24), in which the aforenamed court revoked in its entirety the appealed decision of the Head of the Małopolskie Customs and Fiscal Office in Krakow of 27 December 2023 on the tax on goods and services for the period between January 2015 and June 2015 determining overdue tax liability of ZM SILESIA in the amount of PLN 34.9 million, plus interest and with reference to later reports, advises that on 9 October 2025 it became aware of the ruling issued the same day by SAC in which the court dismissed the cassation appeal of the Head of the Małopolskie Customs and Fiscal Office in Krakow and the prosecutor’s cassation appeal, holding that there had been no effective suspension of the statute of limitations for all tax liabilities sought under the proceedings in question.
Legal grounds:
Article 17 section 1 MAR – Confidential information.
Signatures:
Wojciech Kowalczyk – President of the Management Board
Translation from the original Polish version.
In the event of differences resulting from the translation, reference should be made to the official Polish version.