Poland has released a draft law for public comment which includes an anti-avoidance rule in regard to dividends qualifying for participation exemption. The rules are based on recent anti-abuse rules added to the EU Parent-Subsidiary Directive, which are to be transposed in the domestic legislation of EU Member States by 31 December 2015.
The rule essentially states that Poland will not provide tax exemption for dividends if connected with an arrangement or a series of arrangements where the …