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The Ministry of Finance and the National Revenue Administration (KAS) announced a package of measures aimed at limiting aggressive tax planning in Poland and the transfer of profits outside the country. The priority is to be not the “quantity” but the “quality” of audits – fewer proceedings, but conducted in a targeted manner, based on in-depth risk analysis, with particular emphasis on transfer pricing (TP), which is considered one of the main areas of aggressive tax planning in Poland. The announcements were made during the press briefing of the Minister of Finance on 31 July 2025.
At the Małopolska Customs and Tax Office in Kraków, a Competence Centre for combating aggressive tax planning in Poland in CIT will be established. The unit’s task will be to provide operational and methodological support to the National Revenue Administration (KAS) – including, among others, the development of analytical approaches, the standardisation of practice, and the transfer of knowledge in transfer pricing (TP).
The Centre’s activities will be focused on strengthening the effectiveness of KAS in combating unlawful mechanisms, in transfer pricing. To this end, the Centre’s experts will draw on best practices developed through cooperation with the external environment, including international partners, to counteract aggressive tax planning in Poland more effectively.
The Minister of Finance also announced the establishment of a team whose task will include, among others, the preparation of legislative proposals aimed at making it more difficult for multinational enterprises to use transfer pricing to reduce CIT, which constitutes one of the key elements in the fight against aggressive tax planning in Poland.
The Ministry of Finance is reallocating resources to areas of the highest fiscal risk and is investing in staff development. It is also changing performance metrics – the focus is to be on the monetary effects, not merely the number of proceedings. Aggressive tax planning in Poland is coming to the forefront in intragroup transactions, including:
According to the Ministry, adjustments in the area of transfer pricing are growing rapidly – in the first half of 2025, identified CIT understatements were approximately 30% higher than in the whole of 2023, which demonstrates the effectiveness of measures targeting aggressive tax planning in Poland.
KAS less frequently initiates audits but identifies risk more precisely and more effectively adjusts tax bases. Audits are initiated following in-depth risk analysis (SAF-T, TPR, financial statements, comparative data), which reduces the number of incidental cases and shortens the time of examination. The authorities expect taxpayers to provide consistent reasoning, which must correspond with accounting records, budgets, contracts, and arm’s-length calculations. The first summons is more precise and includes measures targeting aggressive tax planning in Poland, including, among others, market tests and justification for incurring expenses on intangible services.
In line with the announced measures, it may be worthwhile for some taxpayers to reconsider the implementation of an APA (Advance Pricing Agreement). This is an agreement on transfer pricing arrangements between the taxpayer and the tax authority. In such an agreement, the authority accepts the choice and method of applying the transfer pricing verification method used in the taxpayer’s dealings with related parties. For taxpayers, APAs may constitute an effective tool for limiting the risks associated with aggressive tax planning in Poland, minimising the possibility of transfer pricing being challenged by the tax authorities.
On 7 August 2025, the Minister of Finance issued an ordinance establishing the Team for Combating Aggressive Tax Planning in Poland in CIT. The Team includes, among others, representatives of the management of the Ministry of Finance and the National Revenue Administration (KAS).
The Team’s tasks include:
The Team is to submit its final report by 31 October 2025 – at this stage, there is no information as to whether the report will be made public.
Legislative initiatives have also been introduced by the President of the Republic of Poland, promoted, among others, under the slogan “PIT Zero. Family Plus.” In addition to changes in PIT, they contain a so-called legislative “insertion” – a proposal to amend the Act on the National Revenue Administration (KAS). According to the concept presented, CIT taxpayers with average annual revenues exceeding PLN 5 billion would be subject to mandatory customs and tax audits in the field of transfer pricing, at least once every three years, as part of measures targeting aggressive tax planning in Poland.
Although at this stage it is only a proposal, it indicates the direction of changes in the legislative process aimed at counteracting aggressive tax planning in Poland, not only on the part of the government.
Accace experts provide comprehensive preparation of transfer pricing documentation (Local File, Master File, TPR), together with reliable benchmarks and arm’s-length tests, in compliance with applicable legal regulations. We support clients at every stage – from the preparation of documentation, through drafting responses to summons, to assistance during a tax audit.
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