WHT compliance

Comprehensive support for businesses navigating WHT obligations

Withholding tax (WHT) in Poland applies to payments made to foreign entities for dividends, interest, royalties, and certain services. Due to recent tightening of regulations—including the pay-and-refund mechanism and the requirement for due diligence—WHT compliance has become a critical area for businesses engaged in cross-border transactions. CRIDO’s tailored services provide end-to-end support for companies managing WHT obligations, ensuring full compliance and minimizing tax risks.

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Scope of the compliance service

Our WHT compliance services include:

1. Implementation compliance support involving assessment of WHT obligations based on transaction type and recipient status.
2. Ongoing compliance: support in fulfilling the withholding tax compliance obligations stipulated by the tax regulations. We will prepare or verify CIT-10Z declarations, IFT-1/IFT-1R and IFT-2/IFT-2R information, or WH-OSC board member statements. Verification of documentation (e.g. residency certificates, beneficial ownership statements).

Benefits of our service

1. Professional support: our team of dozens of experts specializing in withholding tax issues will provide professional advice at every stage of cooperation, from analysis of tax obligations to representation before tax authorities. Projects are actively managed by partners and managers with many years of experience in the industry.
2. Experience: dozens of completed projects, thousands of reviewed documents and many good solutions. We know what works because we have been dealing with the subject of withholding tax for years, and our projects are managed by a team of experienced experts.
3. Individual approach: we do not act in a template – we emphasize an individual approach to each client and tailor our services to their specific needs.
4. Certainty: we carefully analyze the legal situation and propose a recommended course of action, taking into account all relevant aspects of the case. As a result, the client feels confident that tax matters are in the hands of experienced experts.
5. Access to up-to-date knowledge: we take an active part in the creation of changes, come out with legislative proposals or join the work on them. We are among the first to know and speak about the changes. We share our knowledge of planned regulatory changes with our clients.
6. Innovative approach: we develop pioneering solutions to WHT obligations.

Why choose CRIDO?

At CRIDO, we combine technical expertise with practical experience to deliver effective WHT compliance solutions. Whether you’re making outbound payments or receiving income from abroad, our services are designed to protect your business from regulatory risks while optimizing tax outcomes. From strategic planning to hands-on support, we ensure your WHT obligations are met with precision and confidence.

How we work

1. Compliance Assurance: We ensure all required filings and documentation are complete, accurate, and submitted on time.
2. Ongoing Support: We provide continuous updates on regulatory changes and their impact on your WHT obligations.

Additional support services

Analysis of WHT tax obligations: based on the information provided, we will analyze in detail your legal situation in terms of taxation of receivables withholding tax and develop an effective and safe strategy for approaching the subject of withholding tax.

Support in the due diligence process and preparation and verification of tax documentation: we assist clients in the due diligence process and analyze the formal documents required to benefit from withholding tax preferences (certificates of residency, receivable recipient statements).

Analysis of WHT issues for M&A purposes: based on detailed information about the transaction, we will conduct a comprehensive analysis for withholding tax (WHT) issues in the context of the planned transaction. We will develop an effective and safe strategy, taking into account potential risks, to ensure compliance.

Support in drafting contractual provisions minimizing WHT risks: we will conduct an analysis and prepare proposals for relevant contractual provisions relevant to WHT, and actively participate in the negotiation of new contractual clause.

Support in obtaining an opinion on the application of withholding tax preferences: we will guide the client through the entire process of obtaining a withholding tax preference opinion. First, we conduct a detailed analysis of the possibility of applying preferential withholding tax rates, enabling us to assess the chances of obtaining a favorable ruling. Subsequently, our services include the development of a draft application, filing it on behalf of the client, and representation during the proceedings conducted by the tax authority. In the event of a refusal to issue an opinion on the application of preferences in WHT, we provide support at all stages of the dispute pending before the administrative courts.

Support in the recovery of withholding tax: we provide comprehensive support in the process of recovery of withholding tax – both in the case of overpayment of WHT, as well as refund of tax withheld under the pay&refund mechanism (on amounts exceeding PLN 2 million). Our services include both the development and submission of an appropriate application to the tax authority (along with the necessary attachments), as well as support at all stages of the proceedings (including the development of explanations, contacts with the tax authority, support at the stage of recovery).

Representation before tax authorities and administrative courts in matters concerning withholding tax issues: we offer support in the course of verification activities, audits (tax/customs) and tax proceedings – both at the stage of tax authorities and administrative courts. Our support is comprehensive in nature, including: (i) we develop a comprehensive litigation strategy, flexibly adapting it to the client’s needs, (ii) we take an active part in the audit/prosecution, constantly monitoring their course and actions taken, (iii) we look for non-standard solutions, strictly adapted to the Client’s needs.

Constant access to up-to-date tax and legal knowledge: the CRIDOTEKA training platform offered by Crido guarantees access to training videos on, among other things, withholding tax issues, prepared by experienced experts who deal with these issues on a daily basis.