The most important feature of this sanction, which was not accepted by the CJEU, was the automatic application in the case of errors, with no possibility of the authorities lowering the amount in specific cases. In other words, regardless of whether the VAT was declared incorrectly because of a simple mistake or some intentional action, the tax authorities were obliged to apply the same sanction.
It took some time to prepare a proper amendment to the VAT Act, but it has finally been accepted.
Source: mddp.pl
