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...
The proposal indicated in the draft EU Directive will prevent certain shell entities from benefiting from the preferences contained in double tax treaties
On December 22, 2021. The European Commission presented a draft Directive[1] designed to prevent shell entities from unauthorizedly reducing or avoiding tax liabilities through international arrangements contained in double tax treaties. The aim is to prevent shell...
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...
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