In order to apply the exemption, it is necessary to have the appropriate documentation. The basis is the tax residence certificate of the dividend recipient, which confirms their tax domicile. In practice, when using the WHT preference, the payer should also verify and document the status of the ‘beneficial owner’ (BO) of the recipient, with the proviso that the Supreme Administrative Court’s case law is not uniform. A statement of compliance with the conditions for exemption and documents confirming the required share in the capital and the period of its ownership are also necessary. Without these documents, the paying company is not entitled to apply the exemption and must collect the full 19% tax.