Poland: Amendments to transfer pricing regulations; other tax developments
Recent tax developments include changes to transfer pricing rules, tax deductibility of invoices, and a court decision on VAT.
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january 22, 2026
The KPMG member firm in Poland has summarized recent tax developments, including legislative proposals, court decisions, and regulatory updates.
- Amendments to transfer pricing regulations were announced, including changes to the individual (personal) income tax law and corporate income tax law, with relaxed rules for signing transfer pricing report (TPR) information.
- The Director of the National Revenue Administration Information Centre ruled that expenses documented by invoices issued outside the national e-invoicing system (KSeF) may be included in tax-deductible costs if they reflect actual transactions.
- Preliminary remarks to a bill amending the Tax Code were released, aiming to align third-party liability for tax debts with EU law requirements from Court of Justice of the European Union (CJEU) judgments.
- An opinion on top-up taxation was released, clarifying conditions for research and development (R&D) relief as eligible refundable relief under the act on top-up taxation of members of multinational enterprise groups and large-scale domestic groups.
- The Head of the National Revenue Administration denied a clearance opinion on share redemption in a public limited company without remuneration.
- The Anti-Tax Avoidance Council published a resolution assessing transactions involving closed-end investment funds and tax benefits.
- The Supreme Administrative Court (SAC) has held that (1) overstated invoices do not allow for input value added tax (VAT) deduction (I FSK 211/23), (2) corrective notes cannot change transaction parties (I FSK 307/23), and (3) organizing a lottery without promoting alcoholic beverage trademarks did not constitute advertising of alcoholic beverages (I FSK 1971/22).
Read the January 2026 report