The Lead Story
Poland’s Transfer-Pricing Crackdown Gets Serious
The Big Picture: Poland’s tax sleuths are sharpening their pencils,and their scalpels. After years of steady drum-beating about profit shifting, Warsaw is now rolling out specialised units and expert panels to make sure multinationals leave the right slice of income inside the country.
The Details: Irregularities unearthed by transfer-pricing (TP) auditors have almost doubled year-on-year, and in just the first half of 2025 they were already 30 % higher than the whole of 2023, International Tax Review reports. This contrasts sharply with reformative measures seen elsewhere, such as those outlined in the Nigerian Tax Laws 2025 - Comprehensive Tax Reform Legislation. The Ministry of Finance and the National Revenue Administration (KAS) have reacted with a two-pronged plan:
- A new Expert Group for Counteracting Aggressive Tax Planning will draft recommendations across four fronts,from harmful planning patterns to beefed-up international cooperation.
- A KAS Competence Centre in Kraków now hunts down optimisation schemes in real time.
Magdalena Marciniak of advisory firm MDDP told International Tax Review that the authorities are "moving from quantity to quality",fewer audits, but far deeper dives into financial transactions, licensing deals, and business restructurings.
Why It Matters: The reaction was swift across Poland’s tax community. Practitioners warn that TP documentation that looked fine last year may no longer pass muster. With adjusted income figures ballooning, companies can expect more periodic reviews for the largest taxpayers and tighter scrutiny of intragroup loans and intangibles,mirroring the modernized procedures and enhanced taxpayer rights detailed in the Nigeria Tax Administration Act, 2025.
Around the Tax World
- UN treaty negotiations heat up. Delegates in Nairobi opened talks on a draft global tax treaty that could rewrite how digital-age profits are shared, including a pledge to pursue a “fair allocation of taxing rights” (Bloomberg Tax).
- Bybit taps TaxBit for crypto reporting muscle. The exchange will automate tax information for users in 70+ jurisdictions under CARF and the EU’s DAC8 framework, aiming for friction-free compliance (Crypto Briefing).
- ITR World Tax 2027 submission guide drops. Firms eyeing next year’s rankings now have a step-by-step webinar on how to polish their entries (International Tax Review).
By the Numbers
Tax Stat of the Day: 30 %
That’s how much higher Poland’s uncovered TP irregularities were in H1 2025 compared with the whole of 2023, underscoring just how quickly the audit net is tightening.
Looking Ahead
All eyes are now on Warsaw’s draft guidance expected early 2026,and on Nairobi, where negotiators will test whether “fair allocation” is more than just a catchphrase. This evolving global tax landscape echoes the momentum seen in other jurisdictions, as highlighted in Nigeria’s New Tax Playbook Ruffles Aviation, Woos Big Tech.