From September 1, the procedure for offsetting and refunding funds from the Unified Tax System has changed

Effective September 1, 2026, new rules for managing funds recorded in the Single Tax Account (STA) will be in effect. These changes primarily affect situations where a taxpayer wishes to use an existing positive balance to pay another person’s tax obligations or to return funds previously transferred to the STA. These transactions must now consider not only the amount stated in the application but also the recipient’s actual tax liability.

Set-off of funds against the obligations of another person

One of the key changes concerns the ability to offset funds from one taxpayer’s Unified Tax System (UTS) against another person’s obligation. Previously, this mechanism allowed funds to be transferred to another taxpayer, but as of September 1, offsetting is directly dependent on the recipient’s current obligation to the budget. This means that simply having an application and funds in the UTS is no longer sufficient to complete the transaction.

The recipient must be liable for taxes, fees, insurance premiums, penalties, fines, or interest. This applies not only to outstanding debts that are already due. Future payments may also be taken into account if the tax authority already has the relevant declaration, calculation, or tax notice.

Therefore, before transferring funds to another party, their current budget status must be taken into account. If the recipient has neither outstanding debt nor confirmed upcoming obligations, the offset will not be applied.

Moreover, if the amount indicated in the application exceeds the recipient’s existing liability, the tax authority will only credit the portion of the funds corresponding to the liability. In other words, it will no longer be possible to use an amount greater than the actual liability to pay someone else’s tax obligations.

In practice, this means that before applying for a credit, it is worth checking:

• whether the recipient has any outstanding taxes, fees, insurance premiums, penalties, fines or interest;
• whether he has any upcoming obligations confirmed by a declaration, calculation or tax notice;
• whether the amount to be offset corresponds to the amount of the existing obligation;
• whether a situation has arisen in which part of the declared amount will remain uncredited due to the insufficient amount of the recipient’s obligations.

Application requirements

The changes also affect the procedure for submitting an offset application. If the application is submitted through the taxpayer’s personal account, it must be signed with an enhanced qualified electronic signature. Therefore, organizations and entrepreneurs who use the offset mechanism for funds in favor of others must consider not only the presence of a corresponding positive balance of the Unified Tax System but also the requirements for the electronic signature.

This may be especially important for companies that regularly transfer funds for related organizations, group members, or counterparties. If the transaction is conducted electronically, the lack of the required qualified electronic signature may prevent the application from being submitted in accordance with the established procedure.

Refunds from the Unified Tax System

Separate rules now apply to refunds from the single tax account. These changes apply to cases where the positive balance of the single tax account was generated by payments made by third parties on the taxpayer’s behalf.

If such funds need to be refunded, they must be deposited not into any arbitrary bank account of the taxpayer, but into the account from which the funds were originally transferred. Therefore, the source of the positive balance of the Unified Tax System (UTS) is now relevant when making a refund.

This is especially important for companies for which other parties regularly make tax payments. For example, when another company, group member, or other payer transfers funds on behalf of the organization, the original source of payment must be taken into account for subsequent refunds.

As a result, the new order can be reduced to two basic rules:

• when offsetting in favor of another person, the recipient must have a current tax liability;
• When refunding funds , the bank account from which the corresponding payment was originally received is taken into account.

What does this mean for business?

The changes make the management of the positive balance of the Unified Tax System (UTS) more closely tied to the actual status of taxpayers’ settlements with the budget. Previously, when planning an offset in favor of another person, the primary focus was on the availability of funds and the correctness of the application. Now, it is also necessary to assess whether the recipient has a specific obligation to the budget.

For companies that use intra-group settlements or periodically settle tax obligations for each other, this means they need to plan such transactions more carefully. If the recipient does not have the corresponding obligation at the time the application is processed, the expected offset will not occur or will only be applied to the extent of the actual obligation.

When refunding funds, on the other hand, the origin of the positive balance becomes crucial. Therefore, it’s important for companies using third-party payments to maintain information about the accounts from which the relevant amounts were received. This will allow them to correctly determine the refund procedure and avoid problems when managing funds in the Unified Tax System.

In general, starting September 1, when working with a positive balance of the Unified Tax System (UTS), it is necessary to consider not only the amount of funds available to the taxpayer, but also the nature of the transaction, the recipient’s obligations, and the source of the funds. For businesses, this means checking the status of settlements in advance before applying a credit and taking into account the origin of the funds when processing their refund.