Transfer pricing 2026: common mistakes and how to prepare for a tax audit
Is your transfer pricing documentation ready for an audit?
New obligations, increasing activity by tax authorities, and growing emphasis on demonstrating the arm’s length nature of transactions are driving higher transfer pricing risks. During this webinar, we will show what auditors focus on in practice, where irregularities most often occur, and how to prepare for a transfer pricing audit in 2026.
Why is this topic important?
Transfer pricing remains one of the most frequently audited tax areas. Many companies focus on preparing documentation while overlooking issues that, in practice, most often become the subject of disputes with tax authorities.
Inconsistencies between documentation and the actual course of transactions, outdated benchmarking studies, incorrect identification of controlled transactions, or insufficient economic justification for intercompany settlements can significantly increase the risk of tax authorities challenging the applied approach.
What will you learn during the webinar?
Podczas sesji z ekspertką Crowe Poland dowiesz się:
Who should attend?
This event is designed for:
- chief financial officers (CFOs),
- chief accountants,
- tax directors and tax managers,
- members of management boards of companies belonging to capital groups,
- transfer pricing specialists,
- professionals responsible for settlements with related entities.
Don’t wait until an audit uncovers errors that could have been eliminated in advance.
In the area of transfer pricing, the most costly mistakes often result not from a lack of documentation, but from inconsistencies between documentation and the actual conduct of transactions.
Agenda
| Punkt | Temat | Zakres |
|---|---|---|
| 1 |
Transfer pricing audits in 2026 |
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| 2 |
Most common transfer pricing mistakes |
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| 3 |
How to prepare for an audit? |
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| 4 |
Recommendations from Crowe Poland experts |
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| 5 |
Q&A |
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Speaker:
 |
Agata Nieżychowska |
Director, Tax Advisory Department, Crowe Poland Agata has more than 20 years of experience in tax advisory services. Before joining Crowe, she worked with, among others, EY and leading international law firms. She has successfully managed numerous restructuring, mergers and acquisitions, and asset acquisition and disposal projects. At the same time, Agata has extensive experience in comprehensive tax audits and due diligence reviews. She has supervised numerous projects involving international tax planning and tax optimisation for ongoing business operations and investment structures. At Crowe, she is responsible for the tax advisory practice. |
Frequently asked questions (FAQ)
Yes. Registered participants will receive access to the recording after the event.
Yes. We will cover both fundamental topics and more advanced risks that may arise during audits.
No. The content will be relevant to all companies conducting transactions with related parties.
During audits, tax authorities most frequently identify inconsistencies between documentation and the actual course of transactions, incorrect identification of controlled transactions, outdated benchmarking studies, and insufficient economic justification for settlements between related entities. Another common issue is the lack of adequate evidence supporting the transfer pricing methodology applied.
Yes. A benchmarking study is one of the key elements supporting the arm’s length nature of prices applied in transactions with related entities. An outdated or inadequate study may make it more difficult to defend the adopted remuneration level during an audit and increase the risk of adjustments by tax authorities.
Transfer pricing documentation should be retained for the period required under tax regulations. Since tax audits or proceedings may be initiated after the year to which the documentation relates, companies should ensure the secure archiving of both TP documentation and supporting materials confirming how transactions were carried out.
The obligation to prepare Local File documentation applies to taxpayers carrying out specific transactions with related entities once the statutory documentation thresholds have been exceeded. The scope of obligations depends, among other things, on the type and value of the transaction. During the webinar, we will explain when the documentation obligation arises and what elements a Local File should contain.
