Multinational corporations & holding companies managing intercompany loans.

Investors & financial institutions structuring cross-border financing.

Real estate & infrastructure firms funding developments through foreign entities

Corporate tax & finance teams ensuring compliance and minimizing risks.

CZECH REPUBLIC

The maximum withholding tax rate is applicable on interest paid to foreign entity residing in jurisdiction with which double tax treaty was not concluded and to foreign entity residing in jurisdiction considered non-cooperative for tax purposes.

HUNGARY

The maximum withholding tax rate is applicable on interests paid to foreign entity residing in jurisdiction considered non-cooperative for tax purposes or in jurisdiction with corporate income tax rate below 9%. Such interest represent an item increasing the tax base; exemption from obligation to increase the tax base may be applied under specific conditions.

POLAND

Pay and refund mechanism; If interest repaid to foreign related entity exceeds PLN 2,000,000 per year, standard withholding tax rate of 20% applies on the excess of PLN 2,000,000, regardless of the right to benefit from more beneficial withholding tax rate or exemption (provided that the tax remitter submitted neither withholding tax statement nor has obtained an opinion on tax preferences from the tax office). A withholding tax refund may be applied for.

ROMANIA

The maximum withholding tax rate is applicable on interest paid to foreign entity residing in jurisdiction considered non-cooperative for tax purposes.

SLOVAKIA

The maximum withholding tax rate is applicable on interest paid to foreign entity residing in jurisdiction with which double tax treaty was not concluded and to foreign entity residing in jurisdiction considered non-cooperative for tax purposes.

UKRAINE

The general 15% withholding tax rate applies.

CZECH REPUBLIC

In addition to the conditions imposed by the EU Interest & Royalty Directive, the company receiving the interest must be granted a decision on withholding tax exemption by the tax office.

HUNGARY

Only conditions imposed by the EU Interest & Royalty Directive must be fulfilled for application of the withholding tax exemption.

POLAND

Only conditions imposed by the EU Interest & Royalty Directive must be fulfilled for application of the withholding tax exemption.

ROMANIA

In addition to the conditions imposed by the EU Interest & Royalty Directive, the company receiving the interest must be granted a decision on withholding tax exemption by the tax office.

SLOVAKIA

In addition to the conditions imposed by the EU Interest & Royalty Directive, the company receiving the interest must be proved as an ultimate beneficiary of this income.

UKRAINE

N/A

CZECH REPUBLIC

Notification on income paid abroad and tax withheld and remitted must be filed with the tax authority within set deadlines. If the exemption from withholding tax applies, no reporting obligation arises in respect of interest payments of less than CZK 300,000 per calendar month to a single creditor.

HUNGARY

Notification on income paid abroad and tax withheld and remitted must be filed with the tax authority within set deadlines.

POLAND

Notification on income paid abroad and tax withheld and remitted must be filed with the tax authority within set deadlines.

ROMANIA

Notification on income paid abroad and tax withheld and remitted must be filed with the tax authority within set deadlines.

SLOVAKIA

Notification on income paid abroad and tax withheld and remitted must be filed with the tax authority within set deadlines.

UKRAINE

Reporting obligation is fulfilled within the annual corporate income tax return filing.