Poland: Public consultations on beneficial owner for withholding tax purposes, expansion relief measures

Ministry of Finance announced public consultations

Ministry of Finance announced public consultations

The Ministry of Finance on 28 September 2023 announced public consultations (until 10 October 2023) on draft clarifications of:

  • Beneficial owner clause for purposes of withholding tax, in particular:
    • Method of interpreting and applying CIT Act and PIT Act provisions on collecting withholding tax by remitters, in the wording applicable as of 1 January 2022
    • Interpretation of the notion of “beneficial owner”
    • Framework of the remitter’s due diligence
  • Tax relief under Article 18eb of the CIT Act and Article 28gb of the PIT Act, commonly referred to as expansion or pro-growth relief

Read an October 2023 report prepared by the KPMG member firm in Poland



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