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Poland: Application of provision exempting dividends from withholding tax (Supreme Administrative Court decision)

Provision may still apply if dividend recipient enjoys exemption from taxation of dividend income

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June 10, 2025

The Supreme Administrative Court on May 30, 2025, held (case file II FSK 1489/24) that Article 22(4)(4) of the CIT Act, which exempts dividends paid by Polish companies to entities in other European Union (EU) or European Economic Area (EEA) member states from withholding tax, does not apply when the dividend recipient is exempt from income tax on their worldwide income (regardless of where earned). However, the exemption may still apply if the dividend recipient enjoys an object-related exemption, such as an exemption from taxation of dividend income.

Read a June 2025 report prepared by the KPMG member firm in Poland

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