Exemptions from withholding tax depend on who the beneficial owner of the payment is. If the beneficial owner cannot be identified, the tax will have to be withheld at the rate of 20%. Cashpooling is a very popular cash management tool among corporate groups. The idea is for subsidiaries with excess cash to transfer their surpluses to those with cash deficits on their accounts. Such transfers can be made at the close of each business day, with the funds coming back to their owners the next day. Treating its cash position as a common pool of cash, the entire group can achieve savings as it does not need to use external funding for its operations.

For the full text of the article by Grzegorz Myłnarczyk, tax advisor and Sendero Tax & Legal partner, see Rzeczpospolita on-line: https://bit.ly/3y3Xovq.