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 […]
Category: WHT
Withholding Tax on Dividends – Recent Polish Developments
Tomasz Napierała
0
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 […]