We provide advisory services grounded in our extensive experience and strong expertise in tax regulations under international tax treaties and foreign domestic laws. Through close cooperation with leading international tax and legal firms, we provide comprehensive support to clients engaged in cross-border operations. Withholding tax (WHT) is a core area of our international tax practice.

Withholding tax is a key element of international tax compliance, applying to payments made to foreign counterparties, such as dividends, interest, royalties, and remuneration for certain intangible services. The obligation withhold tax at the standard domestic rate often creates a significant financial burden, which may be mitigated by applying domestic exemptions or double tax treaties.

Polish regulations and the administrative practice of tax authorities impose a range of requirements on payers seeking to apply exemptions or preferential WHT rates, especially where payments are made to related parties.

Our withholding tax team provides comprehensive support in meeting these obligations, from assessing transactions from a WHT perspective, through assisting with formal requirements, including preparing relevant documentation and conducting due diligence checks, to representing clients in proceedings before tax authorities and administrative courts.

We provide support, in particular, in the following areas:

• Cross-border transactions
• International financing structures (cash pooling/netting)
• Permanent establishments (PEs)
• Taxation of controlled foreign companies (CFCs)
• WHT procedure - exercising due care
• Clearance opinion on the application of WHT preferences
• WH-OSC statements
• Refunds of WHT overpaid by foreign investment and pension funds
• WHT refunds under the pay-and-refund mechanism