Category: WHT

If a Polish company has obtained a refund of withholding tax (WHT) under the Polish pay-and-refund regime, it may also be possible to recover the late-payment interest paid together with that tax. This position has recently been confirmed by the Polish courts. Recovering WHT is not always the end of the story Since 2022, Poland […]

On 3 July 2025, the Ministry of Finance issued tax clarifications on applying the Beneficial Owner (BO) clause for withholding tax (WHT) purposes. This document is of crucial importance for entities paying dividends, interest or royalties to foreign recipients.   Definition of the beneficial owner For clarity, under the Polish law a Beneficial Owner is […]

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 […]