The Opole-based National Tax Administration has detected serious irregularities in the CIT settlements of an international pharmaceutical company. After the audit, the company corrected its declarations and paid more than PLN 11.5 million in outstanding tax with interest.
KAS has detected irregularities in CIT. Multinational pharmaceutical company surcharges PLN 11.5 million
Published Nov. 25, 2025 11:47
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Experts from the Opole Customs and Tax Administration conducted an audit at a multinational company in the pharmaceutical industry, covering CIT settlements for 2019-2021. Analysis of the documentation revealed irregularities regarding both transfer pricing and withholding tax (WHT).
As the auditors found, the company set a non-market interest rate on bonds issued to a related party. According to the regulations and the provisions of the double tax treaties, this non-marketable portion of the interest could not benefit from a reduced withholding tax rate.
In addition, it was stated that the funds obtained from the bond issue were used to acquire shares in another related party, which was subsequently merged with the controlled company. According to the Corporate Income Tax Law, interest on bonds used for such a purpose is not tax deductible.
After reviewing the audit's findings, the company agreed with KAS's conclusions, filed corrections to its returns and voluntarily paid nearly PLN 11.5 million in overdue CIT plus interest.
What is withholding tax (WHT)?
WHT ( withholding tax) is a levy collected by payers on certain categories of income, such as dividends, interest or royalties. In Poland, it applies to both corporate and personal income tax.
Source: Ministry of Finance
