Relief at source - eligibility, documentation, deadlines - Polish equities and ETF

Tax | Poland

Reference

Service level

6-series account | CBL

Last Updated

25.09.2026

Who can obtain relief at source?

Tax relief at source on dividends from Polish Equities is available through Clearstream for the following beneficial owners:

Beneficial owners		Equities
Domestic legal entities		0%^a
Foreign legal entities	Central banks	DTT rate
	Governments, administrative subdivisions and local authorities	DTT rate
	Banks and investment firms (as defined in EU MiFiD regulations)	DTT rate
	Insurance companies	DTT rate
	Supranational or international organisations of which Poland is a member	DTT rate
	Entities mentioned in DTT (example of these entities in DTT Poland/Singapore)	DTT rate
	DTT resident pension funds and investment funds	DTT rate
	EU investors with substantial holding	0%
Eligible pension funds and investment funds ^b		0%

a. Domestic legal entities are paid gross, and they should settle withholding tax themselves

b. From 1 January 2026, a 0% rate applies to all funds (not only EU/EEA) domiciled in a jurisdiction whose legal framework allows Polish authorities to obtain information on accounts held by the fund though an automatic exchange mechanism.

Documentation requirements

To obtain relief at source on dividends a complete set of correctly completed documents must be provided by the required deadline.

Upon submission of the relevant documentation, the depository will perform a due-diligence analysis and confirm via email whether a reduced tax rate (or tax exemption) can be applied.

The documentation requirements are described below and the templates of the forms are available under Tax Forms to use - Poland section.

a) FOR ALL ELIGIBLE BENEFICIAL OWNERS

Per-payment instruction

Per-payment instruction per each tax rate provided via Swift (formatted MT565) or Xact Web Portal Message that includes:

Client Account Number
ISIN
Corporate Action Reference ID
Payment Date
The total holding of securities
Full name, fiscal address, and TIN number of the Beneficial Owner
Country of Residence for Tax Purposes
Tax rate to apply
Holding for which the reduced/exempt tax rate applies

The beneficial owner per-payment instruction must be provided before each dividend payment.

Specificity for domestic legal entities

For domestic legal entities, only the instructions above containing shareholding information is required.

Specificity for EU investors with substantial holding

For EU investors with a substantial holding, all requests will be assessed on a case-by-case basis with current tax regulations and other requirements taken into account. There is no standard set of documentation.

b) IN ADDITION, FOR ALL BO (EXCEPT DOMESTIC LEGAL ENTITIES)

One-time certificate (OTC) for equities

The original One-time certificate is completed and duly signed by the client. It specifies among other things whether the client is the sole beneficial owner of all the equities held in the account. It must be provided once before the first income payment.

It remains valid for 5 years. Any changes to any details must be communicated in a new OTC.

c) IN ADDITION, DEPENDING ON THE TYPE OF BO

Type of BO	Documentation required (English language only)
Foreign central banks	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration) Notarised copy of company establishment documents Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor ‘s opinion will be accepted only if such an opinion has not been issued.
Foreign banks and investment firms (as defined in EU MiFiD regulations)	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration). One of the following: Notarised copy of an extract from recipient’s commercial registrar, OR if not available Notarised copy of company establishment documents. One of the following: Notarised copy of a banking/investment firm license, OR Notarised and apostilled Statement confirming the status of the bank/investment firm with reference to the publicly available official registrar that confirms the scope of its license (Statement C-RAS Declaration). Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor's opinion will be accepted only if such an opinion has not been issued.
Insurance Companies	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration) One of the following: Notarised copy of an extract from recipient’s commercial registrar, OR if not available Notarised copy of company establishment documents. One of the following: Notarised copy of license, OR Notarised and apostilled statement confirming the status of the insurance company with reference to the publicly available official registrar that confirms the scope of its license (Statement C-RAS Declaration) Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor ‘opinion will be accepted only provided that such opinion has not been issued.
Entities specifically mentioned in the DTT signed between Poland and their country of residence	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration) One of the following: Notarised copy of an extract from recipient’s commercial registrar, OR if not available Notarised copy of company establishment documents. Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor’s opinion will be accepted only if such an opinion has not been issued.
Foreign governments, foreign administrative sub-divisions and foreign local authorities	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration) Notarised copy of establishment documents Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor ‘opinion will be accepted only if such an opinion has not been issued.
Supranational or international organisations of which Poland is a Member	Notarised and apostilled beneficial owner statement (Statement B - RAS Supranational Declaration). Notarised copy of company establishment documents (upon request).
Pension Funds and Investment Funds	Up-to-date Certificate of Tax Residence (original or copy) Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration) One of the following: Notarised copy of an extract from recipient’s commercial registrar, OR if not available Notarised copy of company establishment document. One of the following: Notarised copy of a license, OR Notarised and apostilled statement confirming the status of the pension/investment fund with reference to the publicly available official registrar that confirms the scope of its license (Statement C-RAS Declaration) For pension/investment applying for full exemption: additional notarised and apostilled statement from beneficial owner (Statements F – Investment Fund Statement/D – Pension Fund Statement) Latest financial statements together with the auditor’s opinion (if such opinion is available). Financial statements without the auditor’s opinion will be accepted only if such an opinion has not been issued.

Important Note: Investors who obtained a ruling from the Polish Tax Authorities on the applicability of the DTT rates must provide a copy of such ruling together with their certification for review and evaluation. Then an original or notarised copy of such ruling will be required.

Power of Attorney – Omnibus account

A Power of Attorney should be provided if a third party is completing the Declaration of Beneficial Ownership. The document must be provided once before the first applicable income payment and remains valid until revoked.

Deadlines for receipt of documents¹

In order to benefit from relief at source, eligible beneficial owners should provide the required documentation within the below prescribed deadlines. If any instruction, tax certification or amendment is received after these deadlines, the client's entire application for relief at source will be rejected. It may then be possible to process the application via the quick refund.

Relief at source	Deadline for receipt by Clearstream
Original certificates	At the latest, Ten business days before the payment date by 10:00 CET.
Per payment instruction	At the latest, Two business days before the payment date by 10:00 CET.

Clients will be informed no later than one business day before the payment date in the event of non-approval of a beneficial owner by our depository.

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1. Clients are strongly recommended to verify the deadlines of each event in our tax notifications, as those may be subject to changes upon the request of the issuer.

Relief at source - eligibility, documentation, deadlines - Polish equities and ETF

Who can obtain relief at source?

Documentation requirements

Deadlines for receipt of documents1

Deadlines for receipt of documents¹