Fewer Transfer Pricing Audits, Higher Reassessments – How the Tax Authorities’ Approach Is Changing

Data obtained from the Polish Ministry of Finance on transfer pricing audits in 2025 confirms a trend we have observed in practice for several years: the number of transfer pricing audits is declining, while their effectiveness is increasing – the value of reassessments rose by approximately 16% compared to 2024.

The conclusion is straightforward: tax authorities are auditing less often, but far more effectively.

At the same time, the way audits are conducted is changing. A few years ago, the key question was: was the price set at market level? Today, authorities increasingly ask: does the transaction have a genuine economic rationale and does it add value to the group?

Increasingly, the greatest risk is not the price itself, but the lack of a convincing answer to the question of why the transaction exists in the first place. This is particularly visible in licensing arrangements, financing, and intra-group services, where authorities examine not only the level of remuneration but also the business rationale of the services and the benefits obtained by the recipient.

Our experience shows that audits increasingly begin with an analysis of the company’s activities, its role within the group, and the actual course of the transaction. Formal correctness of TP documentation alone is not enough – even the best Local File will not defend a settlement model that has no reflection in economic reality.

In transfer pricing, it is increasingly not the transaction price that is scrutinised, but the business logic behind entering into it.

If you would like to assess whether your TP documentation and settlement model would withstand this type of audit, we invite you to contact our transfer pricing team.