The New WHT (Withholding Tax) Landscape: Guidelines, Rulings, and Practical Challenges!
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On Tuesday, the AmCham Tax & Financial Services Committee held a meeting to discuss the impact of the WHT (Withholding Tax) guidelines issued last year on US group structures, as well as the important general tax rulings released in November 2024.
These developments may significantly affect companies operating within US-based groups, including joint ventures, and could reshape how WHT is managed in Poland.
We began the session by addressing practical questions, including how tax authorities may assess complex group structures in practice, what businesses need to do to properly verify payments before applying WHT exemptions, and how and when to determine whether a foreign recipient qualifies as the beneficial owner.
We then discussed which aspects of the new guidance are favorable for taxpayers, where risks still remain, and how the changes impact common payment streams such as dividends, interest, royalties, and service fees.
Thank you to our speakers from KPMG, Sabina Samplawska, Mariusz Kułagowski; Andrzej Zyga, Mariusz Głodek; the Co-Chairs of the Committee, Adam Soska, Tomasz Lenart, and everyone who joined us and shared their perspectives.
SPEAKERS
Sabina Sampławska
Mariusz Kułagowski
Andrzej Zyga
Mariusz Głodek
