Does the progressive digitalization of service of documents ensure the efficiency of tax proceedings without prejudice to the taxpayer’s rights? The Sham of Legal Acts in Tax Law

The article analyzes the impact of progressive digitalization of service on the efficiency of tax proceedings and the protection of taxpayer rights. The author demonstrates that contrary to the Electronic Service Act’s objectives of unifying communication channels, practice has led to a multiplication of parallel systems (eDelivery, PUESC, e-US, municipal platforms, ePUAP). Article 144 1a of the Tax Ordinance establishes an ambiguous hierarchy where agencies’ IT systems take precedence over electronic service addresses, effectively marginalizing the unified system. This multiplicity forces taxpayers to monitor several independent mailboxes, increasing the risk of missing important correspondence and violating procedural guarantees. Particularly problematic is administrative courts’ rejection of complaints filed via eDelivery as not meeting formal requirements, despite their status as equivalent communication means. The author advocates for functional interpretation of procedural provisions respecting the constitutional right to court and the actual purpose of digitalization reforms, while calling for urgent legislative action to genuinely unify electronic communication channels in tax proceedings