Poland: Withholding tax guidelines related to application of “beneficial owner clause”

An analysis of the most important issues discussed in the withholding tax guidelines

The Ministry of Finance on July 9, 2025, published tax guidelines related to the application of the “beneficial owner clause” for withholding tax purposes.

Key withholding tax issues addressed in the guidelines include:

Having the status of and being covered by the definition of beneficial owner as prerequisites for enjoying preferential withholding tax treatment
Scope of payments subject to the requirement of verifying the beneficial owner status
Circumstances tested to verify the beneficial owner status
Criteria for assessing the applicability of a preferential rate, exemption, or non-collection of withholding tax
Specific scenarios for verifying the beneficial owner status, namely:
- The look-through approach
- Broadened entity-related criteria for verifying the beneficial owner status
- Presumption of meeting the beneficial owner criterion
- Collective Management Organizations (CMOs) and their beneficial owner status

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

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Poland: Withholding tax guidelines related to application of “beneficial owner clause”

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