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Poland - Holding via a Partnership Ineligible for Exemption under the EC Parent-Subsidiary Directive

Country:
Poland
Author:
Filip Świtała
Issue:
European Taxation, 2009 (Volume 49), No 7
Published:
6 July 2009
The author, in this note, presents a critical view of a surprising judgment of the Warsaw District Administrative Court in a case concerning the exemption from dividend withholding tax of the profits distributed by a Polish subsidiary company to its Netherlands parent company holding the shares in subsidiary via a German limited partnership. In the case, the court decided that such a holding does not qualify for the exemption under the EC Parent-Subsidiary Directive.
 
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