This is a page for the tag WHT Poland
MDR changes in Poland 2026: what companies must do before 1 October
From 1 October 2026, Poland’s Mandatory Disclosure Rules (MDR) will generally apply only to reportable cross-border arrangements. VAT and excise arrangements will fall outside the MDR framework, while the separate supporting-party role and the statutory requirement to maintain an internal MDR procedure will be removed. Companies should nevertheless reassess participant... Read More →
Transfer pricing and withholding tax in Poland: when do they affect each other?
Under Polish tax law, transfer pricing can directly affect withholding tax in Poland when a Polish company pays interest or royalties to a foreign related party. A WHT exemption or reduced rate may apply only to the arm’s length portion of the payment. Any excess may trigger both a transfer... Read More →
Tax deregulation in Poland: what Deregulation 2.0 may change for businesses
Tax deregulation in Poland under the announced Deregulation 2.0 package may simplify selected tax procedures, but it does not remove the taxpayer’s responsibility for correct settlements. The key proposals include pre-filled VAT returns, e-receipts issued through a free mobile application, a 5-year validity period for individual tax rulings, broader use... Read More →
Pay and Refund in Poland – a complicated withholding tax (WHT) refund procedure
The pay and refund in Poland mechanism is a withholding tax procedure that requires careful preparation, proper documentation analysis and strict compliance with statutory deadlines. In practice, it may significantly affect companies making cross-border payments from Poland, especially within international capital groups. Below we explain what the Polish pay and... Read More →
Withholding tax in Poland in numbers: what 2025 WHT statistics show
Withholding tax in Poland in numbers shows that WHT is no longer merely a technical obligation connected with cross-border payments. The 2025 statistics confirm that withholding tax remains one of the most sensitive areas of tax settlements in Poland — both in terms of the number of documents filed and... Read More →
Withholding tax (WHT) in Poland 2026 – a comprehensive guide
Withholding tax (WHT) in Poland 2026 is one of the key tax risk areas for companies making cross-border payments. It primarily applies where a Polish company pays amounts to a foreign contractor, shareholder, lender, licensor or another entity that is not a Polish tax resident. In practice, WHT may arise... Read More →
Withholding tax (WHT) on hosting services in Poland – Supreme Administrative Court of Poland (NSA) judgment
Withholding tax (WHT) has once again become one of the key issues for businesses in Poland making payments to foreign contractors. Following earlier disputes over digital and cloud-based services, this direction has been reinforced by judgments of the Supreme Administrative Court of Poland (NSA) issued in 2025. Of particular importance... Read More →
Withholding tax (WHT) in Poland: WH-OSC statements should not be filed too early
Withholding tax (WHT) remains one of the most sensitive areas of tax compliance in cross-border transactions under Polish tax law. Particular attention is required when applying the pay and refund mechanism, which – once a statutory payment threshold is exceeded – generally obliges the payer to withhold tax at the... Read More →
Tax residency certificate as a condition for applying a Double Taxation Agreement (DTA) to withholding tax (WHT) in Poland – Polish Supreme Administrative Court (NSA) ruling
A tax residency certificate is now a key document for Polish withholding tax (WHT) payers. It determines whether the preferences of a Double Taxation Agreement (DTA) can be applied or whether tax must be collected at the domestic rate. The judgment of the Supreme Administrative Court (NSA) of 20 August... Read More →
Withholding tax and foreign income in Poland – the Supreme Administrative Court decides how to calculate the withholding tax deduction limit
In its judgment of 28 May 2025 (II FSK 1131/22), confirmed that when settling withholding tax (WHT) paid abroad in Poland, the deduction limit under Article 20(1) of the CIT Act refers to income earned in a foreign country, not to revenue. The ruling was made in a case involving... Read More →
