On 3 July 2025, the Ministry of Finance published tax explanations regarding the application of the beneficial owner (BO) clause for withholding tax (WHT) purposes. This document is of key importance for all entities paying dividends, interest and royalties to foreign contractors. Definition of the beneficial owner As a reminder, we point out that […]
Category: WHT
Withholding Tax on Dividends – Recent Polish Developments
Tomasz Napierała
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Recent months have brought a number of important developments in Polish case law and tax authority interpretations concerning withholding tax (WHT) on dividends. While some rulings offer hope for a more taxpayer-friendly approach, inconsistencies and ongoing uncertainty continue to pose significant challenges. Below, we highlight key issues and recent decisions that impact cross-border payments from […]