Tax Alert – withholding tax (WHT)
What should be the content of the tax residency certificate?
Pursuant to Art. 4a(12) of the Corporate Income Tax Act, the tax residency certificate is a certificate stating the taxpayer's place of residence for tax purposes, issued by a competent tax administration authority of the taxpayer's country of residence. The...
The services of secondment of employees of group companies are included in the list of revenues subject to withholding tax (WHT)
The subject of the court ruling issued by the WSA in Gliwice on 13 January 2021 (ref. I SA/Gl 1338/20) was the qualification of the services of secondment of employees to the relevant category of revenue indicated in Article 21 of the Corporate Income Tax Act....
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...
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...
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...
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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