Application of the look-through approach concept in Poland – new tax rulings and interpretations
Practical comments on beneficial owner, treaty shopping, beneficial owner clauses for dividends, beneficial owner clauses for interest, substitute companies and abusive clauses, the status of a beneficial owner in various types of intermediary centres between service orderers and service providers, withholding tax on interest paid within the cash pooling structure.
Kieltyka Gladkowski KG Legal - 16 January 2025