Court holds late tax advance payments are tax arrears subject to late fees under Polish tax law.

The Supreme Court allowed the taxpayer's extraordinary review appeal, overturning the lower administrative court's decision to disallow late fees. The court found that unpaid advance payments constitute tax arrears under the Tax Obligations Act, making late fees applicable from the due date. The decision rejected the lower court's reliance on a precedent regarding partial-year assessments, establishing that post-year-end adjustments for incorrect annual filings do not negate the obligation to pay late fees on missed monthly advances.