Transfer pricing audits in 2025

In mid-2025, the Head of the National Revenue Administration (KAS) noted that the amount of additional tax revenue assessed from taxpayers during transfer pricing audits reached 572 (EUR 140M)million PLN. Based on KAS data, the full year ended with a total of nearly 890 million PLN (EUR 210M). Although the number of audits conducted in 2025 decreased, the average reassessment amount increased, reaching a level that was twice as high as in 2023.

Audits in 2025 maintained a high level of effectiveness, indicating that auditors were very well prepared and that taxpayers were effectively selected for audit. Nearly 60% of the transfer pricing audits ended with the transfer pricing assessments.

In mid-2025, a Competence Center was established within the KAS to coordinate the activities of the Central Audit Office (UCS) and improve communication and knowledge sharing. Since these efforts are aimed at further improving the effectiveness of audits, we can expect an increase in their number and a reduction in their duration.

The coordination of audits conducted by the UCS may also result in a very precise verification of individual solutions used by taxpayers that systematically raise concerns for the KAS. Consequently, a reversal of the trend of recent years and an increase in the number of audits in 2026 can be expected.