Conducting cross-border business activity, and in particular functioning in Poland of business entities with foreign capital is connected with the necessity to develop principles of tax risk management in the area of withholding tax and international tax law.
The stiffening of the premises identifying the beneficial owner of benefits paid abroad as of 1 January 2019 and the introduction of new, very strict rules for the collection of withholding tax (with a significant limitation of the possibility of direct application of a tax exemption or a lower tax rate) posed numerous challenges to Polish taxpayers of this tax.
Based on our knowledge and many years of experience we support entrepreneurs in preparing for the new legal situation. We advise in terms of establishing the identification of the actual owner and the tax consequences of paying dividends, interest, royalties and other payments abroad (Dr Michał Wilk is an expert on the subject – he is the author of the only monograph on the Polish market on the actual owner clause).
We prepare procedures for our clients to apply due diligence in determining the prerequisites for the withholding tax exemption or reduced tax rate.
We also advise in other areas of international tax law, prepare expert tax opinions and represent our clients before tax authorities and administrative courts – including recovery of overpaid withholding tax in Poland.
Contact: dr Michał Wilk, Jakub Wirski