Exemption of dividends from withholding tax without the requirement of beneficial ownership status – significance of the Head of the National Tax Information Service’s ruling

Exemption of dividends from withholding tax without the requirement of beneficial ownership status – significance of the Head of the National Tax Information Service’s ruling

Corporate tax, Trochę o CIT

The condition of beneficial ownership has remained one of the key issues in withholding tax for many years, particularly in the context of applying exemptions provided for in the CIT Act. The legislator explicitly made the exemption from withholding tax on royalties and interest conditional upon beneficial ownership. In practice, however, tax authorities tend to…