In late July this year the Ministry of Finance and Economy and the National Revenue Administration held a press briefing to discuss new strategies and ideas in combating aggressive tax planning and transfer pricing schemes.

The officials said that the additional income assessed as a result of tax audits and investigations conducted in 2024 (which businesses tried to exfiltrate from Poland) represented an increase of nearly 100% while the revealed tax evasion through transfer pricing was 30% bigger than in the entire 2023. What is more, irregularities are detected in as many as 98% of tax audits and 94% of customs and tax audits.

Finance Minister Andrzej Domański announced they are setting up a special task-force within the National Revenue Administration, tasked with issuing a comprehensive report by October 2025 with legislative proposals to end the profit shifting process.

One of the measures is to establish a Competence Centre for Aggressive Tax Planning (to be seated in Kraków) whose responsibilities will include:

  • monitoring intercompany transactions within groups;
  • analysing MDR disclosures;
  • conducting operations and analytic work both domestically and internationally;
  • providing expertise to support auditing and investigative units.

Companies that are members of groups, have foreign associations or use preferential tax treatments should expect increased scrutiny by tax authorities.

We will be pleased to assist you in checking if:

  • your local file and master file for transfer pricing purposes are up to date, fully compliant with Polish regulations and true to facts;
  • your group’s transfer pricing policy is suitable for your business profile and your intercompany pricing and billing models are in accordance with the arm’s length principle;
  • your company or group would benefit from having internal procedures in place for verification of intercompany transactions or from holding a source documents review;
  • a tax risk analysis is advisable or necessary for your restructuring transactions (e.g. mergers, divestitures, non-cash equity contributions) (if you are planning any).

If this issue pertains to your business and you are interested in our assistance, please contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.