MDDP on Polish Taxes I Webinar - Withholding tax - Analysis of the business substance of foreign entities

As of 2019 Polish rules on withholding tax [WHT] were subject to a revolutionary change which is still not yet fully explained and commented by tax authorities and practitioners. One of the most important components of that change were requirements of due diligence on the side of Polish payers, including verification of beneficial ownership status of foreign taxpayers (payment recipients). A crucial element of beneficial ownership is local genuine business activity, the so-called substance. The issue shall be even more important starting from 2022 when stricter rules will be eventually effective to intra-group passive payments exceeding PLN 2 Mio per annum.

Justyna Bauta-Szostak, partner and Jacek Wojtach, senior manager in the MDDP Income Taxes Team will talk about what is required in particular with respect to substance condition and how it should be documented, during the next webinar on “MDDP on Polish Taxes” series.

The meeting will be held in English. Webinar is free of charge.

During the webinar, among others, the following points shall be discussed:

  1. Overview of due diligence and beneficial ownership conditions (including substance).
  2. Key points of 2022 pay and refund regime applicable to >PLN 2 Mio p.a. payments and why substance shall be even more important in that situations.
  3. Case study – vague substance regulations in Polish laws and how they are understood by Polish tax authorities:
    • local key and daily management,
    • infrastructure, including office, equipment and software,
    • personal substance – employees, service providers,
    • costs, documentation, books.
  4. How to document substance, which approach to take.
  5. How to secure tax position? Withholding tax clearence, statements – what else?
The “Withholding tax – Analysis of the business substance of foreign entities” webinar is a free online seminar addressed to MDDP clients and business partners. The number of places is limited. The organizer reserves the right to refuse to accept the application.
After confirming the acceptance of the application by e-mail, in the next e-mail you will receive an individual link to the website where the MDDP WEBINAR will be held.

I want to participate in the MDDP webinar on October 21, 2021 at 10:00 a.m.

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25.11.2021, 10.00 CET: Intellectual property in the context of TP and tax planning / structures

02.12.2021, 10.00 CET: Changes in VAT in Poland – central register of invoices, structured invoices and other changes