We use cookies to personalise the website and offer you the greatest added value. They are, among other purposes, used to analyse visitor usage in order to improve the website for you. By using this website, you agree to their use. Further information can be found in our data privacy statement.

Polish Deal – changes to withholding tax (WHT)


by Klaudia Bielecka

20 September 2021


The draft Polish Deal, which has been recently submitted to the lower chamber of Polish parliament (Sejm), modifies the withholding tax regulations. The changes include:


  • narrowing the application of the WHT refund procedure to passive income (e.g. royalties, interest or dividends) paid to associated enterprises;
  • allowing opinions to be issued not only on tax exemption under income tax acts but also on preferential rates (reduced tax rates) under tax treaties;
  • clarifying the principles of due care to be exercised when applying a reduced tax rate or exemption, in particular for payments made to associated enterprises;
  • allowing the withholding agent to sign the statement in accordance with the rules of its representation;
  • clarifying the definition of beneficial owner.

The new regulations are to apply from 1 January 2022. Withholding agents should already start preparing for the new regulations.


Contact Person Picture

Monika Bartosiewicz

Tax adviser (Poland)

Associate Partner

Send inquiry


Deutschland Weltweit Search Menu