Poland tightens transfer pricing oversight: what’s coming next?
In recent months, transfer pricing has become a key focus for tax authorities in Poland. Although the number of audits has declined, the focus is sharper. The rising amounts of adjusted taxable income and the creation of new structures within the Ministry of Finance and the National Revenue Administration (Krajowa Administracja Skarbowa, or KAS) show that related-party transactions – and potential profit shifting outside Poland – have become a top government priority.
Irregularities in financial transactions, licensing agreements, transactions involving intangible assets, services, or business restructurings in Poland may, in particular, expose taxpayers to transfer pricing audits.
Combating aggressive tax planning
In transfer pricing, the value of adjusted income, representing profits shifted abroad, has almost doubled year on year. In the first half of 2025 alone, uncovered irregularities were already 30% higher than in all of 2023. In response, the Ministry of Finance and KAS have intensified their efforts to counter aggressive tax planning.
A special Expert Group for Counteracting Aggressive Tax Planning in Corporate Income Tax was established to prepare recommendations for strengthening the system. It will focus on four key areas:
- International corporate income tax frameworks;
- Harmful planning patterns;
- Systemic safeguards; and
- International cooperation.
At the same time, the authorities launched the KAS Competence Centre in Kraków. This specialised unit identifies and neutralises optimisation schemes.
These initiatives are part of a broader effort to curb aggressive tax behaviour and reinforce the integrity of the tax system.
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Poland tightens transfer pricing oversight: what’s coming next? | International Tax Review.