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Reform Support
© EU

Supporting reforms to ensure efficient and effective revenue administration and public financial management

Funding Programme
  • 2019

Strengthening the capacity in transfer pricing in Poland

The Commission supported the Polish National Revenue Administration in tackling erosion of the tax base caused by inaccurate application of transfer pricing rules. Targeted capacity building aims at supporting the Polish tax administration’s efforts to address the challenges related to aggressive tax planning and misuse of transfer pricing.


The Polish National Revenue Administration was seeking to enhance the tax officials’ skills in effective application and implementation of transfer pricing rules. Building sustainable capacity in transfer pricing risk assessment, audit and dispute resolution should ensure an efficient tax revenue collection in the longer term.

Support delivered

The Commission facilitated access to tailored expert support with the following support measures:

  • Development of an internal capacity-building program for tax officials;
  • Analysis of selected transfer pricing issues based on case-study training sessions;
  • The exchange of good practices with other EU Member States administrations in the area of transfer pricing, large taxpayers and cross-border dispute resolution.

Results achieved

The Commission’s technical support contributed to an effective implementation of existing transfer pricing rules by building sustainable administrative capacity within the Polish National Revenue Administration. The support measures strengthened the knowledge and expertise in the area of transfer pricing.