The Anti-Abuse Clause and the Parent-Subsidiary Dividend Exemption

May the tax authority deny the dividend withholding tax exemption to a company that formally satisfies all the conditions set forth in Article 22(4) of the Polish Corporate Income Tax Act, invoking instead the anti-abuse clause contained in Article 22c? The Voivodeship Administrative Court in GdaƄsk answered in the affirmative – yet simultaneously, aligning itself … Continue reading The Anti-Abuse Clause and the Parent-Subsidiary Dividend Exemption