What do the new regulations concern?
The new regulations in force from 2019 impose on the entities executing payments exceeding PLN 2 million annually the obligation to collect withholding tax regardless of the potential application of exemptions or reliefs resulting from double taxation agreements.
The provisions relate to interest payments, dividends, royalties, remuneration for low value-added services paid to non-residents.
New project of regulation
According to the published on 10.12.2018 regulation of Finance Minister, related to exclusions and restrictions, the obligation will not apply until the end of June 2019 in relation to the payment for dividends, interest and intangible services, and until the end of December 31, 2019 in respect of payments for royalties or international passenger and freight transport. The assumption is the existence of an international agreement providing a basis for exchange of tax information.