Withholding tax in Poland in numbers: what 2025 WHT statistics show

Withholding tax in Poland in numbers shows that WHT is no longer merely a technical obligation connected with cross-border payments. The 2025 statistics confirm that withholding tax remains one of the most sensitive areas of tax settlements in Poland — both in terms of the number of documents filed and the value of funds that may temporarily remain outside the taxpayer’s control.

Data on applications for opinions on the application of WHT preferences, WH-OSC statements, tax refunds and corrections relating to previous years point to several important trends. Companies are more often securing their settlements in advance, making greater use of refund procedures and reviewing earlier tax periods. In practice, this means that WHT requires not only correct classification of payments, but also a well-documented decision-making process.

More information on the WHT mechanism itself, payments subject to withholding tax, payer obligations and the rules for applying tax preferences can be found in our detailed guide: Withholding tax (WHT) in Poland 2026 – a comprehensive guide.

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WHT in Poland in 2025 – why the data matters for businesses

The 2025 WHT statistics are relevant not only for tax advisers and finance departments. They also have direct practical importance for businesses making payments to foreign contractors, related parties, shareholders, lenders, licensors or other non-residents.

In practice, withholding tax in Poland may apply, among others, to:

• dividends,
• interest,
• royalties,
• selected intangible services,
• certain payments made within capital groups,
• selected financial and ownership-related transactions with foreign entities.

The 2025 data shows that businesses increasingly treat WHT as an area requiring systematic management. It is no longer only about checking a tax residency certificate or applying the correct tax rate. Equally important are verification of the beneficial owner status, exercising due diligence, assessing whether an exemption or reduced rate may be applied, and documenting the entire process.

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782 applications for opinions on WHT preferences – growth and the effect of cyclicality

In 2025, a total of 782 applications for opinions on the application of WHT preferences were submitted to the Lublin Tax Office (Lubelski Urząd Skarbowy). This number included:

• 629 WH-WOP applications submitted by withholding tax remitters,
• 153 WH-WOZ applications submitted by taxpayers.

This represents a clear increase compared with 2024, when 662 applications were filed. At the same time, the figure remains significantly lower than in 2022, the first year in which the new rules applied, when the authority received 1,374 applications.

This structure may indicate a cyclical effect. Opinions on the application of WHT preferences are issued for a specific period, which means that some taxpayers and remitters in 2025 may have been renewing protection obtained earlier, particularly during the initial period of the new rules.

From a business perspective, an opinion on the application of WHT preferences remains an important risk-limiting tool. It allows preferential tax treatment to be applied without collecting tax under the pay and refund mechanism, provided that the required conditions are met.

However, this does not mean automatic security. Preparing an application requires proper argumentation, documents and information confirming the right to apply preferential treatment. In larger capital groups or in the case of high-value payments, consistency between tax, contractual and financial documentation is also essential.

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2,322 WH-OSC statements – a faster path, but greater responsibility

One of the most visible figures for 2025 is the number of WH-OSC statements. A total of 2,322 statements were submitted during the year, compared with 2,131 in 2024 and 2,126 in 2023. This means that after a period of relative stability, there was a more noticeable increase in interest in this route for securing WHT settlements. The WH-OSC statement is a faster solution than waiting for an opinion on the application of WHT preferences. It allows the remitter not to collect tax or to apply preferential taxation rules, but it also involves significant responsibility for the persons signing the statement.

In practice, the management board or persons authorised to represent the remitter confirm that they:

• hold the required documents,
• have carried out the required verification,
• have no knowledge justifying the assumption that there are circumstances excluding the application of WHT preferences.

From a business point of view, the increase in WH-OSC statements shows that companies are looking for solutions that are more flexible and faster from an operational perspective. At the same time, this route should not be treated as a simple administrative formality. If the verification process has not been carried out reliably, the statement may increase both personal and tax risk.

For this reason, many companies need to organise their internal WHT procedure: who initiates the analysis, who collects documents, who assesses the counterparty’s status, who approves the application of preferences, and who is responsible for archiving materials in case of a tax audit.

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WHT refunds: over PLN 2.44 billion returned to taxpayers

One of the most important conclusions from the 2025 data is the scale of withholding tax refunds. In total, more than PLN 2.44 billion in WHT was returned to taxpayers.

This amount consisted mainly of two areas:

• refunds under the pay and refund mechanism,
• overpayments identified under the Polish Tax Ordinance.

In 2025, 604 refund applications were submitted under the pay and refund mechanism, and the total amount of refunds granted exceeded PLN 1.13 billion. This mechanism generally applies to payments exceeding the PLN 2 million threshold made to a single taxpayer.

Even stronger dynamics can be seen in the area of applications for confirmation of overpayment. In 2025, the Lublin Tax Office reviewed 4,440 cases, with 4,207 new applications submitted. The amount of confirmed overpayments exceeded PLN 1.3 billion, compared with approximately PLN 787 million in 2024.

This is an important signal for businesses. The growing value of refunds shows that companies are more often choosing a cautious approach: first collecting tax and then seeking a refund. This model may reduce certain tax risks, but it also affects liquidity.

In practice, withholding tax collected at source may mean that significant funds are frozen for many months. For companies making regular cross-border payments — especially within capital groups — this may have a real impact on financial management, dividend planning, intragroup financing or royalty settlements.

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The pay and refund mechanism and corporate liquidity

The pay and refund mechanism is particularly important for high-value payments. If the remitter cannot apply preferential treatment at the payment stage, it collects tax at domestic rates, after which the taxpayer or remitter may apply for a refund.

From the perspective of the Polish tax authorities, this mechanism strengthens control over the application of WHT preferences. From the perspective of businesses, however, it creates a significant administrative and financial burden.

A company must:

• determine whether a given payment is subject to WHT,
• assess whether the PLN 2 million threshold has been exceeded,
• analyse whether an exemption or reduced rate may be applied,
• collect documents confirming the right to apply preferential treatment,
• prepare a refund application,
• be prepared for additional questions from the tax authority,
• take into account the time required to obtain a decision.

The 2025 data shows that refund mechanisms are not a marginal element of the system. They involve amounts counted in billions of Polish zlotys. For companies, this means that cash flow planning and WHT analysis should take place before a payment is made, not only at the final transfer stage.

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WHT reporting and corrections for previous years – the growing role of tax reviews

Another important element of the 2025 statistics is the increase in the number of CIT-10Z declarations and IFT-2R information forms filed. In 2025 alone, more than 16,000 CIT-10Z forms were submitted, compared with around 14,000 in 2024.

Part of this increase may be explained by the natural growth in the number of entities doing business in Poland. However, this is not the only explanation. The data also shows the growing importance of documents relating to previous years.

This may indicate that historical WHT settlements are being reviewed more frequently. Companies are analysing earlier payments, verifying documentation, assessing whether preferences were applied correctly and — where necessary — filing corrections or additional forms.

This trend is logical in the current Polish tax environment. WHT is an area in which risk does not always emerge at the moment a payment is made. It may arise later, for example during a tax review, group audit, due diligence process, tax authority audit or a change in interpretation regarding the beneficial owner of a payment.

For this reason, businesses should treat WHT not only as a current obligation, but also as an area requiring periodic verification. This applies in particular to companies that have been making similar foreign payments for years under recurring agreements.

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Refusals in WHT cases and the risk of tax audits

At first glance, some of the 2025 data may suggest an improvement in taxpayers’ position. The number of refusals to issue opinions on the application of WHT preferences fell from 72 in 2024 to 24 in 2025. The number of refusals concerning tax refunds under the pay and refund procedure also decreased — from 34 to 28.

However, these figures should not be interpreted as a sign that WHT has become a low-risk area. The decrease in refusals may result from several factors. Taxpayers may have prepared applications better, used more organised documentation or been more cautious in selecting cases in which they decided to use the procedure. WHT explanations may also have provided the market with a clearer point of reference.

At the same time, the general direction of the Polish tax administration remains selective and focused on areas with a high potential for additional tax assessments. In 2025, the number of customs and tax audits decreased, but the value of findings from those audits increased. This means that authorities select cases more carefully, while focusing on areas where potential irregularities may have significant value.

WHT fits this audit model well. It concerns cross-border payments, often high-value transactions, capital links, holding structures, group financing and licensing arrangements. These are areas in which the authorities may examine the economic rationale of transactions, beneficial owner status and the justification for applied preferences in detail.

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Beneficial owner status remains a key point of analysis

One of the most important practical issues in WHT remains the status of the beneficial owner of the payment. The 2025 data does not change this conclusion, but it does show its practical importance.

Verification of beneficial owner status should not be limited to a formal statement from the counterparty. Depending on the circumstances, it may be necessary to analyse whether the recipient of the payment:

• receives the payment for its own benefit,
• is not merely an intermediary,
• conducts genuine business activity,
• bears the economic risk connected with the receivable,
• has appropriate organisational and decision-making substance,
• does not transfer the payment further in a way that indicates an artificial structure.

For businesses, this means that the analysis must go beyond the tax residency certificate alone. The certificate is an important document, but on its own it does not determine the right to apply WHT preferences. A broader view of the transaction, the counterparty and the purpose of the payment is required.

Documentation is particularly important in this area. If, several years later, the tax authority challenges the applied preference, the company should be able to show the basis on which it decided not to collect tax or to apply a lower rate.

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What do the 2025 WHT statistics mean for companies?

The 2025 data leads to several practical conclusions.

First, WHT remains an area of significant financial value. Refunds exceeding PLN 2.44 billion show that withholding tax has a real impact on corporate liquidity.

Second, the importance of protective procedures is increasing. The growing number of opinions on the application of WHT preferences and WH-OSC statements indicates that companies are increasingly looking for formal or procedural ways to reduce risk.

Third, businesses are more often returning to historical settlements. The rise in documents relating to previous years may indicate a growing number of audits, corrections and reviews of earlier payments.

Fourth, the decrease in refusals does not mean that audit risk is falling. The authorities continue to focus on high-value and high-risk areas, and WHT clearly belongs to this category.

Fifth, WHT should not be analysed only by the tax department. In practice, it requires cooperation between finance, accounting, management, legal teams and those responsible for related-party relationships and foreign contractors.

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How to prepare your company for WHT settlements in the coming years

The 2025 statistics show that companies should approach WHT as a structured process. The greatest risk is not only an incorrect tax rate, but also the inability to demonstrate that the company acted with due diligence.

In practice, it is worth verifying in particular:

• what types of foreign payments occur in the company,
• whether payments are correctly classified for WHT purposes,
• whether the PLN 2 million threshold for a given taxpayer is monitored,
• whether the company holds up-to-date tax residency certificates,
• whether beneficial owner status is verified,
• whether a procedure exists for applying exemptions and reduced rates,
• whether WH-OSC-related decisions are properly documented,
• whether previous tax years require review,
• whether documentation is available and organised in case of an audit.

For companies making regular cross-border payments, an internal WHT matrix may also be helpful. Such a document makes it possible to assign types of payments to the relevant tax rules, define required documents, indicate responsible persons and standardise the company’s approach.

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WHT as an area of tax risk management

WHT is increasingly rarely treated as a single accounting activity. In practice, it is becoming an element of tax risk management in the company.

This applies especially to businesses that:

• operate in international capital groups,
• pay dividends abroad,
• use intragroup financing,
• pay interest, royalties or fees for intangible services,
• make payments to holding companies,
• use double tax treaties,
• apply exemptions resulting from EU regulations.

In such cases, WHT should be considered already at the transaction planning stage, not only when the transfer is made. This allows the company to assess tax consequences in advance, collect documents and reduce the risk of later corrections or disputes with the authorities.

For more complex cross-border payments, companies may consider working with getsix® in the area of withholding tax support in Poland, particularly when analysing remitter obligations, verifying WHT documentation and assessing the possibility of applying tax preferences.

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Withholding tax in Poland in numbers for 2025 shows that WHT remains one of the most important tax areas for companies involved in international transactions. The growing number of WH-OSC statements, the high value of refunds, the increasing importance of overpayments and the higher number of documents relating to previous years all point to one conclusion: businesses are managing this area more actively, but the scale of risk remains significant.

The most important conclusion for companies is practical. WHT requires an organised procedure, up-to-date documentation and periodic verification. Simply repeating the existing settlement approach may no longer be sufficient, especially where payments involve related parties, holding structures, financing or royalty arrangements.

getsix® supports businesses in analysing withholding tax settlements, preparing documentation, assessing the right to apply preferences and reviewing current and historical cross-border payments. A properly designed WHT process can reduce tax risk, improve settlements and strengthen the security of decisions made by management. Contact us.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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