Tax Alert 10/2025: The Ministry of Finance intensifies efforts to combat the CIT budget gap

In mid-August 2025, the Team for Combating Aggressive Tax Planning and the KAS Competence Centre (based at the Lesser Poland Customs and Tax Office in Kraków) commenced operations – new bodies established by the Minister of Finance and Economy in close cooperation with the Head of the National Revenue Administration (KAS).

Their activities are will focus on combating aggressive tax optimisation in corporate income tax (CIT), particularly with regard to cross-border settlements. The Ministry explains that this initiative responds to the high effectiveness of transfer pricing audits in recent years, emphasising that transfer pricing remains the most commonly used tool by taxpayers to reduce their taxable income.

The Team will be responsible for developing solutions, including proposals for legislative amendments, in the area of combating aggressive CIT tax planning, based on analyses of, among other things, international CIT tax systems and harmful tax planning schemes.

At the same time, the tasks of the KAS Competence Centre will include, among others, analysing information prepared by the Team, as well as collecting and processing data from the JPK-CIT and KSeF systems.
These actions suggest that, in the coming years, taxpayers should expect a targeted selection of CIT taxpayers for audits, intensified verification activities, and an increased number of corporate income tax audits.

In light of the above, we recommend reviewing your CIT tax settlements, with particular emphasis on the international aspects of transactions, including withholding tax (WHT), especially in dealings with related parties. Please note that the tax authorities are entitled to review CIT settlements that have not yet become time-barred (i.e., as a rule, settlements for the last six years).