Poland: Poland introduces substance test for payments to recipients abroad

As stated in the April issue of ITR, payments from Poland to a foreign entity subject to withholding tax (WHT) exceeding PLN 2 million ($500,000), will be subject to a standard 19% WHT rate. Such a recipient qualifying for an exemption or reduced WHT treaty rate, or in some cases WHT remitter, can apply for a WHT refund. The threshold will apply to one recipient per year. The date of introduction of these rules was deferred to January 2020.

Źródło: ITR