Polish Court Limits Exemption for Dividend Payments to Swiss Parent
A recent decision by the Polish Supreme Administrative Court clarified the application of the Poland- Switzerland tax treaty and the EU parent-subsidiary directive, as subsequently amended, to dividend payments made in 2011 by the Polish subsidiary of a Swiss parent company. The Court held that dividends paid before 2012 could not benefit from the withholding tax exemption otherwise provided by the directive (Council Directive 90/435/EC of July 23, 1990).
To read in fulll please use the link below: