Tax audits in the area of withholding tax (WHT) up by 75% – is your company in the risk group?

Why is this report crucial for your company?

Withholding tax remains one of the key areas of interest for the tax authorities. The dynamic increase in the number of tax audits and the significant amounts of additional assessments show that companies are increasingly coming under the tax authorities’ scrutiny. 
 

What will you find in the report?

✅ Analysis of data from withholding tax audits carried out in 2025 
✅ Key trends in tax authority activity 
✅ Factors increasing the risk of a tax audit 
✅ Conclusions arising from the Ministry of Finance’s Tax Explanations 
✅ Key WHT issues in administrative court rulings in 2025 

Key takeaways:

💡 The number of audits is growing at the fastest rate on record (+75% y/y) 
💡 Withholding tax audits are carried out exclusively by customs and tax offices 
💡 Highest‑risk areas: passive payments to related parties and holding structures 
💡 WH‑OSC statements and opinions on the application of WHT preferences remain important tools for accessing preferential WHT treatment 

Who is this report for?

✔ Chief Financial Officers (CFOs) 
✔ Tax Directors / Tax Managers 
✔ CIT / WHT specialists 
✔ Management Board members 
✔ Individuals responsible for tax compliance 

The report has been prepared by a team of tax experts specialising in tax controversy and WHT advisory:

Aleksandra Mazur‑Zych 
Attorney‑at‑law, Local Partner, Litigation and Arbitration

Krystian Szymaniak 
Partner Associate, Tax Advisory

Mateusz Raińczuk 
Partner Associate, Tax Advisory

Don’t wait until the tax authorities knock on your door 

👉 Download the report now