Clearstream1 informs clients that effective
1 January 2026
adjustments to the documentation requirements for the tax Relief at Source (RAS) service on equities, bonds and T-bills will take effect for a specified group of investors (i.e. foreign central banks, foreign governments or administrative subdivisions, foreign banks and investment firms, supranational organisations, entities mentioned in a double taxation treaty (DTT) as tax exempted, investment funds and pension funds and insurance companies).
These measures follow the publication on 9 July 2025 of the guidelines on beneficial ownership for withholding tax relief by the Polish Ministry of Finance (A25055).
Eligible investors who expect the current tax RAS service to be continued from 1 January 2026 are required to submit the following documents by 29 December 2025:
- Updated Certificate of Tax Residence (CoTR), as applicable
- The confirmation that previously provided documents/statements are still valid (as practiced in previous years).
- New documents as marked in bold in the table below, appropriate to the entity type of beneficial owner:
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 ‘opinion will be accepted only provided that such 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 company 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 provided that such 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)
- Notarised copy of extract from recipient’s commercial registrar,
OR if not available
Notarised copy of establishment documents (notarised).
- Notarised copy of 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, which confirms such scope of the banking/investment firm 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.
|
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).
|
Entities specifically mentioned in the double taxation treaty 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)
- Notarised copy of extract from recipient’s commercial registrar OR if not available, 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 provided that such opinion has not been issued.
|
Pension Funds and Investment Funds | Eligible EU/EEA based investment and pension funds: - 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.
- Notarised copy of licence
or
Notarised and apostilled statement confirming the status of the pension/investment fund and reference to the publicly available official registrar, which confirms such scope of the pension/investment fund licence (Statement C-RAS Declaration) - For pension/investment funds from EU and EEA applying for full exemption: additional notarised and apostilled statement from beneficial owner (Statements F – Investment Fund and statement D - Pension Fund Statementa)
Other than the above-mentioned investment and pension funds - Up-to-date Certificate of Tax Residence (original or copy )Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration)
- Notarised copy of extract from the recipient’s commercial registrar
or
if not available, notarised copy of establishment documents. - Notarised copy of licence
or
Notarised and apostilled statement confirming the status of the pension/investment fund and reference to the publicly available official registrar, which confirms such scope of the pension/investment fund licence (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.
|
Insurance Companies | - Up-to-date Certificate of Tax Residence (original or copy)
- Notarised and apostilled beneficial owner statement (Statement A-RAS BO Declaration)
- Notarised copy of extract from the recipient’s commercial registrar
or if not available
Notarised copy of company establishment documents - Notarised copy of licence
or
Notarised and apostilled statement confirming the status of the insurance company and reference to the publicly available official registrar, which confirms such scope of the insurance company licence, including also link to such insurance company’s own website (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.
|
a Pension and investment funds statements F and D provided until end of 2025, if confirmed by investor as still valid, will be accepted. For new pension and investment funds RAS requests (submitted for 2026 RAS), new F/D template will be required.
Impact on clients
The maximum withholding tax rate will apply to dividend/interest payments received on Polish equities, bonds and T-bills for clients who do not provide the relevant documentation by the relevant deadline.
Further information
For further information, please contact the Clearstream Tax Help Desk, Clearstream Client Services or your Relationship Officer.
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1. Clearstream refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Europe AG (for Clearstream Europe AG clients using Creation accounts), registered office at Mergenthalerallee 61, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500. Clearstream Banking S.A. is registered as an Australian CS (Overseas) Facility, under subsection 824B(2) of the Corporations Act 2001, with registration number ARBN 675 244 783.
