The Ministry of Finance is intensifying its efforts against aggressive tax avoidance and the shifting of profits abroad. During a press briefing on July 31, 2025, the Minister of Finance and Economy, Andrzej Domański, together with the Head of the National Revenue Administration (KAS), Marcin Łoboda, presented the achievements to date as well as new initiatives in the fight against tax abuses, particularly those related to transfer pricing.
Visible results
Minister Domański emphasized that improving tax collection efficiency is one of the government’s top priorities. The results are already visible — the VAT gap has decreased from 13.5% to 6.9%, and the effectiveness of KAS continues to rise. In 2024, the income adjusted by tax authorities (in connection with transfer pricing) has nearly doubled. In just the first half of 2025, the results already exceeded those achieved throughout 2023.
The Ministry’s latest actions
The last two initiatives of the Ministry are:
- establishment of a Competence Centre in Kraków – a new hub bringing together experts, advanced tools, and transfer pricing knowledge to better identify companies for audits. The Kraków Centre will focus on five main areas: control, data analysis and technology, knowledge coordination, international cooperation, and relations with business and academia;
- creation of a Special Task Force on Aggressive CIT Tax Planning Using Transfer Pricing – this team will analyze Poland’s tax system in comparison with other countries, identify tax avoidance mechanisms, and propose new legislative solutions to build a more resilient tax system.
Minister Domański emphasized that the actions are directed solely against dishonest entities, not legitimate investors. The goal is to ensure equal and fair conditions for doing business in Poland for all entrepreneurs.
What does this mean for companies?
The companies belonging to capital groups and engaging in transactions with related parties should be prepared for increased scrutiny from tax authorities. As Minister Domański pointed out, this is not about the number of audits, but their quality – meaning businesses must be ready for more thorough and detailed verification.
Therefore, the companies should:
- regularly review their transfer pricing policies,
- ensure complete and accurate transfer pricing documentation,
- systematically verify that transactions with related parties are conducted under arm’s length conditions,
- properly justify pricing methods and cooperation terms,
- identify areas that may raise concerns for tax authorities.
To identify potential transfer pricing risks and develop effective strategies to mitigate them, feel free to contact our TP Team.