Tax Alert ? withholding tax (WHT)

Taxation of sales intermediation services withholding tax

On 29 December 2021, the Director of the National Tax Information issued an individual interpretation with ref. no. 0111-KDIB2-1.4010.441.2021.1.MK on the determination of whether the Representatives' receivables (fee on sales) constitute receivables for advisory...

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Withholding tax for making employees available

In an individual interpretation dated August 13th 2020, mark 0111-KDIB1-1,4010,244,2020.1.ŚS Director of the National Revenue Information System decided that payments for making employees available are subject to WHT and the Company will be obliged to collect a...

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No withholding tax on R&D services

In an individual interpretation, mark 0111-KDIB1-3.4010.272.2020.1.APO, the Director of National Tax Information confirmed as correct the company's position regarding the collection of lump-sum income tax (withholding tax) on payments for R&D services. The...

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Withholding tax for complex services

In the judgment of 17 June 2020, Case No. I SA/Sz 65/20, the Regional Administrative Court in Szczecin indicated that the condition for the application of Art. 21 of uCIT is not the result of payments from a separate (spontaneous) legal relationship, as its...

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Purchasing intermediation services are services similar to consultancy, advertising and market research’ and are consequently subject to WHT and tax deductible limits – position of the WSA in Rzeszów, dated June 4th 2020, ref. I SA/Rz 236/20

The judgment relates to the case concerning a complaint against an individual interpretation. The case concerned a Company specialising in tin recovery. It manufactures pure tin and offers tin alloys and soldering alloys. Due to the fact that industrial waste, which...

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Insurance services are not subject to WHT

Insurance services which are purchased from non-residents are not subject to flat-rate WHT. In the judgment of the Voivodship Administrative Court in Bydgoszcz of 22 January 2020, ref. ISA/Bd 655/19 the court held that insurance services cannot be considered as...

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The taxpayer is obliged to have a statement from the beneficial owner of the taxpayer in each case when it pays interest in the amount exceeding PLN 2,000,000 and, in addition, it should meet additional requirements specified in the provisions of the Corporate Income Tax Act.

On 25 February 2020. The Regional Administrative Court in Łódź, in its judgment under no. I SA/Łd 685/19, dismissed the complaint against the contested interpretation, considering the position presented therein as correct. The dispute in this case concerned two...

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Withholding tax – Due diligence always requires reference to the specific facts and documentation, which may consist in having an independent auditor’s report or obtaining group documents in the case of affiliated entities – Judgment of the Voivodship Administrative Court in Gliwice I SA/Gl 1083/19

On 8 January 2020 this year On 8 January 2020, the Voivodship Administrative Court in the judgment ref. I SA/Gl 1083/19 shared the position of the Director of National Revenue Information, in which it was found that the payer, in addition to meeting the conditions...

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