Report: Transfer Pricing Audits in 2025 – data you need to know before the next audit – Individual tax rulings

Customs and tax offices carried out significantly more successful audits resulting in adjustments than tax offices, which is, among other things, the effect of creating specialized units dedicated exclusively to transfer pricing and conducting in-depth analyses of taxpayers’ business models.

At the same time, administrative court rulings in areas such as licensing fees, intra-group financing, and share redemptions are creating both new risks and tangible defensive arguments for taxpayers. The report helps to understand where the balance currently lies and how to consciously prepare for a potential audit.

The year 2025 confirmed that transfer pricing audits in Poland are entering a new phase. Although tax authorities conducted fewer audits than in the previous year, the scale of income adjustments increased significantly. As a result of audits in 2025, authorities adjusted taxpayers’ income by PLN 875.7 million, compared to PLN 753.1 million in 2024. Moreover, as many as 63% of audits resulted in an increase of declared income.

This increase was not coincidental – in 2025, audits were increasingly preceded by an analysis of the industry, business model, and the taxpayer’s functional profile, with benchmarking and pricing levels assessed only at a later stage.

This is a clear signal that the tax authorities are more effectively identifying high-risk taxpayers and transactions, and that the initiation of an audit increasingly implies a real risk of multi-million adjustments.

From this report, you will learn how transfer pricing audit practices have evolved, which areas are currently at the center of attention of the National Revenue Administration, and how to prepare your organization before the authorities come knocking.

Key benefits – why download the report?

The report shows how, in practice, the approach to selecting and conducting transfer pricing audits has changed – from the use of advanced data analytics and integration of reporting, through the specialization of audit teams, to a focus on transactions with the highest financial risk.

You will learn the latest data on transfer pricing audits in 2025, including adjustments amounting to PLN 875.7 million and the fact that more than 63% of audits result in an increase in income.

You will understand why customs and tax offices now play a key role – they account for as much as 97% of identified income understatements, with an average adjustment of PLN 6.54 million per successful audit.

You will see how audit results vary significantly across regions.

You will learn how the latest case law and individual tax rulings affect key TP areas, such as trademark licensing fees, intra-group loans, transfer pricing adjustments, financial transactions, and share redemptions.

You will learn what initiatives the tax administration is undertaking to effectively prevent tax optimization through the proper application of transfer pricing rules.

The Transfer Pricing Audits 2025 report will be particularly useful for:

• Management board members and business owners responsible for tax strategy as well as financial and reputational risk,
• CFOs, finance directors, and individuals overseeing controlling and treasury functions,
• Tax directors, transfer pricing managers, and tax compliance specialists,
• Leaders in e-commerce and sales operating in IP-based models, central services, distribution, and group logistics,
• Heads of legal departments and internal audit.

If you manage tax risk within a capital group and deal with areas such as licensing fees, intra-group financing, transfer pricing adjustments, or capital operations, the report will help you better understand what authorities and courts are currently focusing on – and how to translate these insights into concrete actions within your organization.

Main sections of the report: