Rafał Kosiń, Adam Rajewski
Rzeczpospolita

The tax changes of the Polish Deal will not be binding on CIT taxpayers with a shifted tax year until the end of their tax year that began before 1 January 2022. It will not always be convenient to defer the effective date of the new regulations this way. This will be the case, in particular, when the new regulations are somewhat less stringent, which is precisely the situation with respect to withholding tax. However, an analysis of the new rules allows the conclusion that entities with a tax year other than the calendar year shall apply the new and more lenient WHT rules as early as from 1 January 2022.