National Revenue Administration’s Competence Centre in Krakow – the taxman’s new approach to transfer pricing audits

This article addresses the following matters:

• Who audits transfer prices?
• What are the methods of verifying transfer prices and what does the new strategy for neutralising aggressive tax optimisation look like?
• What is the new Competence Centre in Krakow tasked with?

The National Revenue Administration (Polish: KAS) is intensifying its activities in the area of transfer pricing. In response to the growing scale of aggressive tax optimisation, the Polish Ministry of Finance launched a new KAS Competence Centre in Krakow in the summer of 2025 – a specialised unit aimed at counteracting fraudulent practices related to shifting profits abroad.

What is the new strategy for combating aggressive tax optimisation in transfer pricing?

In 2024, the value of estimated transfer pricing income in Poland almost doubled compared to 2023. Moreover, in the first half of 2025 alone, this value was already 30% higher than in the entire year of 2023.

In response to the growing challenges faced by tax authorities related to aggressive tax planning, the National Revenue Administration's Competence Centre against aggressive tax planning (hereinafter also referred to as the "Centre") began operating in Krakow on 14 August 2025. This unit operates within the Małopolska Customs and Revenue Office and serves as a specialised analytical centre.

The main tasks of the Centre include:

• analysing information in terms of aggressive tax planning schemes,
• collecting and processing data from the JPK-CIT and KSeF systems,
• developing and transferring best practices to other National Revenue Administration units,
• drafting proposals for legislative changes that make it more difficult for taxpayers to employ aggressive tax strategies,
• promoting good practices throughout the tax administration.

What will the new Competence Centre in Krakow do?

The head of the National Revenue Administration, Marcin Łoboda, noted that the activities of the Competence Centre against aggressive tax planning in transfer pricing are to focus on several areas, including:

• control and operational activities,
• analysis and technology
• expert support.

By utilising modern analytical tools, the National Revenue Administration (KAS) will be able to more quickly identify unusual transactions, especially intra-group transactions conducted within international capital groups. Another important task of the Centre will be to standardise audit procedures across the country and cooperate with foreign tax administrations.

At the same time, the Minister of Finance and Economy (by Order of 7 August 2025) established a Team for combating aggressive tax planning in corporate income tax.

This team is responsible for drafting a report that will propose solutions to combat aggressive tax planning in the corporate income tax (CIT). Through this report, officials hope to:

• analyse international CIT tax systems,
• identify harmful tax planning patterns,
• support the development of the tax system's resilience through systemic actions,
• undertake international cooperation with representatives of other tax authorities.

Summary of changes in transfer pricing auditing in Poland

The Polish Ministry of Finance and the National Revenue Administration remain vigilant about taxpayer activity and are taking new measures that could significantly affect companies required to comply with transfer pricing regulations. This is precisely the area where the largest increase in underreporting and tax avoidance has been observed in recent years.

The tax administration is now gaining access to advanced analytical tools, enabling a much more accurate assessment of transactions between related entities. The JPK-CIT and KSeF systems will play a key role here, providing detailed data on business transactions and the structure of capital and personal relationships. Thanks to specialised analyses conducted by the Competence Centre in Krakow, it will now become possible to quickly pinpoint any deviations from market prices. Each transaction between related entities can be assessed for its economic justification, and potential abuses can be efficiently detected.

This is a clear signal that in the coming years transfer pricing will come into the spotlight for tax authorities, and audits in this area will become more in-depth and effective.