Maciej Grochulski and Piotr Stryjewski analyze why the proposed solutions may, in practice, fail to provide managers with genuine procedural protection. Among other things, they point to the exceptions provided for in the draft legislation, which could significantly limit the ability to challenge findings contained in a tax decision issued against a company. They also note that the planned amendments do not guarantee managers access to the company’s case files, making such access dependent on the authority’s assessment and the company’s consent.