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KSeF and Transfer Pricing Adjustments: Navigating New Transparency and Compliance Challenges for Capital Groups

  • The National e-Invoicing System (KSeF) will significantly increase transparency of business transactions, making all e-invoices, including transfer pricing (TP) adjustments, immediately visible to tax authorities.
  • Capital groups must carefully document and describe TP adjustments in KSeF, as the way these are presented may affect tax authority scrutiny and interpretation.
  • KSeF implementation requires stricter discipline in distinguishing between TP adjustments subject to VAT and those that are not, with detailed documentation needed for corrective invoices.
  • The increased transparency may lead to more frequent and intensive tax audits of intra-group transactions.
  • Capital groups should review and update their transfer pricing policies and systems now to ensure compliance with KSeF requirements ahead of the 2026 deadlines.

Source: crido.pl

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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