New Guidance on the Beneficial Owner clause for withholding tax purposes
27 October 2025
On 3 July 2025 the Polish Minister of Finance published Guidance on the Beneficial Owner clause ("BO") for the purposes of withholding tax ("WHT"). The new Guidance clarifies the interpretation of regulations such as CIT, PIT and double taxation treaties ("DTT"), especially with respect to preferential WHT rates and exemptions arising under DTT and EU directives.
