Skip to main content

Poland: Remitter of dividends obligated to verify authenticity of ownership structure (Supreme Administrative Court decision)

Article 22c of the CIT Act imposed obligation to analyze the authenticity of such structures.

Share
december 23, 2025

The Supreme Administrative Court recently held (case no. II FSK 523/23) that a remitter of dividends is obligated to verify whether the ownership structure under which such dividends are paid is genuine or artificial.

Although, in 2016, the provisions relating to dividends (Article 22(4) of the CIT Act) did not explicitly require the determination of the “beneficial owner,” Article 22c of the CIT Act imposed an obligation to analyze the authenticity of such structures.

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

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline