As of 2019 new refund rules for payments exceeding PLN 2 m. per annum to a given taxpayer and a completely new mechanism of settlement of withholding tax will be in place. In case of dividends the change affects both Polish and foreign recipients. Also, with regard to certain payments not exceeding PLN 2 m. per annum, in order for the remitter to apply the reduced WHT rate some additional requirements will be applicable.
The regulations also introduce new exemptions. For example, withholders shall not be obliged to collect WHT on interest/discount on corporate bonds (if certain conditions are met).
WHT Navigator is a unique digital tool developed by PwC that will help you ensure due diligence required in the new certification process. With the tool you will be able to effectively obtain information required for the certification process from business partners. It can be shared by the withholding agent and the taxpayer.
- Apart from WHT Navigator, we may provide you with the following services:
Identification of applicable changes in new Polish WHT provisions and their impact on the future process of WHT settlements in a particular case (including new obligations and tasks to be imposed on tax remitter as well as risks resulting thereof) to be presented in form of a Memorandum.
- Assistance in the Certification process, during which we may, based on documents and information gathered by the WHT Navigator, help clients in assessment of whether the source information should be considered as sufficient in order to apply the reduced rates or a tax exemption (during this process we may also assist in formal drafting of the relevant statements to be provided to the tax authorities) .
- Assistance during the process of obtaining the Opinion (in case of payments exceeding PLN 2 m. per annum and the potential to apply WHT exemption provided by the CIT Law.
- Assistance during the WHT reclaim procedure – PwC has extensive experience regarding refund procedure for different types of entities. Our team has in-depth knowledge as to the type of documents expected by the tax authorities during various comparability studies.