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Poland publishes Minister of Finance General Ruling on Parent-Subsidiary Directive Subject-to-Tax Requirement for dividends exemption

25 November 2024

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Tax Alerts, National/Federal Taxation, G...

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Poland

In a recent ruling, the Minister of Finance aimed to eliminate discrepancies between how Polish tax authorities and the courts have addressed the application of parent-subsidiary dividend exemptions — particularly with regard to the "effective taxation of dividends."The ruling could help multinational groups seeking withholding tax (WHT) exemptions for dividends from Poland and/or refunds of WHT paid in the past. Following months of intensive discussions with business representatives, on 18 November 2024 the Minister of Finance published a general ruling concerning the conditions for applying the dividend exemption specified in Article 22(4)(2) and (4) of the Corporate Income Tax (CIT) Act...