Poland’s Ministry of Finance has published Tax Clarifications of 3 July 2025 on the application of the beneficial-owner (BO) clause for withholding tax (WHT) purposes. The guidance issued under the Tax Ordinance Act, is intended to give taxpayers and withholding agents safe-harbour protection when followed.
Key points include:
- The BO condition aligns with the OECD and EU concepts and applies to passive payments (dividends, interest, royalties) as well as certain payments under Polish sourc…