EQUITIES – TAX PROCESSING FOR OMNIBUS ACCOUNTS
Information on the tax processing rules relating to mortgage bonds and to other debt instruments are
contained in separate documents.
Table of Contents
1. Tax documents for dividends and other cash distributions relating to shares in corporate
profits ............................................................................................................................. 1
2. Tax obligations and rights for equities .............................................................................. 2
3. Tax Relief at Source for equities........................................................................................ 2
4. Tax Quick Refund for equities – processing of withheld tax prior to remittance
to relevant Tax Office ...................................................................................................... 5
1. Tax documents for dividends and other cash distributions relating to shares in corporate profits
All the tax documents listed below:
 Require official notarisation and certification via an apostille or legalisation, as applicable;
 Are deemed effective and valid for a period of 12 consecutive months from the date of the
signing of the declaration, or until notification of its cancellation to KDPW (does not include
any potential specific tax declarations other than U101, U102, U106, U107, submitted by the
Taxpayer). The Taxpayer shall be obliged to inform KDPW of any changes of circumstance
confirmed in the submitted tax declaration taking place in the 12-month period from its initial
signing.
1. Tax declaration forms submitted by Taxpayers seeking a tax exemption.



U101 – Tax Declaration – Foreign Investment Fund (CIT) – all securities (CIT)
U102 – Tax Declaration – Foreign Pension Fund (CIT) – all securities (CIT)
U106 – Tax Declaration - Qualified holders - equities (CIT)
It will also be possible to submit another specific Taxpayer declaration, i.e. of another legal
entity than mentioned above, confirming its right to a tax exemption. This declaration should
define the status of the Taxpayer and the legal basis for the exemption from income tax.
2. Tax declaration form entitling to the application of the relevant double taxation treaty (DTT)

U107 – Tax Declaration – CIT and PIT Taxpayers – relates to payments of dividends and other
cash distributions relating to shares in corporate profits, on the basis of the relevant DTT.
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
2. Tax obligations and rights for equities
NON-RESIDENT
 CIT TAXPAYER
TAX EXEMPTION:
 Investment Fund, Pension Fund, Qualified holder
 Other special entities seeking tax relief
Disclosure and a relevant Tax Declaration required
NON-RESIDENT
 CIT TAXPAYER
 PIT TAXPAYER
DTT TAX RATE
Disclosure and a relevant Tax Declaration required
RESIDENT PL
 CIT TAXPAYER
TAX EXEMPTION:
 Qualified holder, Investment Fund, Pension Fund
Disclosure and a relevant Tax Declaration required
RESIDENT PL
 PIT TAXPAYER
STANDARD PIT RATE (19%)
Disclosure not required
UNDISCLOSED TAXPAYER
 CIT TAXPAYER
 PIT TAXPAYER
STANDARD TAX RATE (19%)
 CIT RATE - 19%
 PIT RATE - 19%
3. Tax Relief at Source for equities
Chart 1: Relief at Source – tax breakdown for payments of dividends and other cash distributions
relating to shares in corporate profits
Non-Disclosure of Taxpayer
PIT Taxpayers
CIT Taxpayers
Full Disclosure of Taxpayer
Non-Resident
CIT Taxpayer
Non-Resident
PIT Taxpayer
PL Resident
CIT Taxpayer
Certificate of Residence
Tax Declaration
U101, U102, U106
or other specific
Tax Declaration U107 (DTT)
Tax Declaration
U106
Beneficial Owner (BO) Disclosure
19%
0%
DTT Tax rate
0%
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
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Table 1: Deadline for submitting information to KDPW related to Relief at Source processing
Submission of information
Deadline
Equities
W-3 (working days) before 12:00 CET
W – Payment date
PROCESSING OF NON-RESIDENTS CIT AND PIT TAXPAYERS (NON-POLISH RESIDENTS) – RELIEF AT
SOURCE FOR EQUITIES
1. Tax rates from income from payments of dividends and other cash distributions relating to shares
in corporate profits for Non-Residents, CIT and PIT Taxpayers depend on whether these are
disclosed or undisclosed Taxpayers.
a) For undisclosed Taxpayers, the standard tax rate of 19% is applied for both CIT Taxpayers and
PIT Taxpayers,
b) For disclosed Taxpayers, the tax rate depends on the applicable right to tax relief:
i. 0% tax rate – tax exemption applies for specific categories - CIT Taxpayers:
 Investment Fund from EU/EEA country (Tax Declaration U101);
 Pension Fund from EU/EEA country (Tax Declaration U102;
 Qualified holders (Tax Declaration U106) - the Taxpayer holds a set share in the
capital of the issuer;
 Other entitled entity than the entities described above (specific Taxpayer
declaration required).
ii. The DTT tax rate applied to non-Polish CIT and PIT residents on the basis of DTT
agreements1, concluded between the Republic of Poland and the Taxpayer’s tax domicile
(Tax Declaration U107).
2. A condition of applying a lower tax rate than the standard 19% rate for equities, is:
a) the submission by non-Polish CIT and PIT residents of the following documents, within the
deadline sets by KDPW (see Table 1) via the omnibus securities account holder:
i. A Relevant Tax Declaration (U101, U102, U106, U107), entitling to a tax exemption or to
the application of a DTT rate. Tax declarations will be deemed effective and valid by KDPW
for a period of 12 consecutive months from the date of the signing of the declaration, or
until notification of its cancellation to KDPW. The Taxpayer shall be obliged to inform KDPW
of any changes of circumstance confirmed in the submitted tax declaration taking place in
the 12 month period from its initial signing.
ii. Or of another specific declaration submitted by the Taxpayer confirming the tax status held
and providing the legal basis entitling to the exemption from income tax. For this type of
declaration, the rule that it shall be deemed effective and valid for a period of 12 months
1
The list of DTT agreements is available here: http://www.finanse.mf.gov.pl/abc-podatkow/umowymiedzynarodowe/wykaz-umow-o-unikaniu-podwojnego-opodatkowania
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
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shall not apply, unless KDPW, in taking into account the contents of the declaration and the
specific circumstances, shall decide otherwise.
iii. Valid tax residence certificate. A tax residence certificate, which does not indicate any
validity period, shall be deemed to remain valid for a period of 12 consecutive months from
its date of issue, on condition that during this period the Taxpayer’s tax domicile remains
unchanged. If the tax domicile were indeed to change, the non-Polish resident Taxpayer
shall be obliged immediately to provide KDPW with a new and valid certificate of residence.
A certificate of residence will need to be submitted to KDPW via the omnibus securities
account holder, either in its original form or as a notarised copy. A notarised copy requires
certification via an apostille or legalisation, as applicable.
b) disclosure of the Taxpayer by the holder of the omnibus securities account – this consists of
the omnibus securities account holder submitting the Taxpayer’s personal details to KDPW
within the set deadline (see Table 1), separately for each corporate event. This is performed
using an electronic message template. BO Disclosure message includes in particular: BO
details, ISIN, number of securities. The scope of disclosed personal details is derived from
Polish tax regulations, which define disclosure obligations for KDPW in its role as withholding
agent.
3. Notice: Failure to disclose the Taxpayer will result in the standard 19% tax rate being applied for
CIT and PIT Taxpayers.
PROCESSING OF POLISH RESIDENTS BEING CIT TAXPAYERS (LEGAL ENTITIES)
1. Polish resident CIT Taxpayers (legal entities) are obliged to pay tax at source on income from
payments of dividends and other cash distributions relating to shares in corporate profits. In such
instances, KDPW performs the role of withholding agent.
2. The condition for Polish Resident CIT Taxpayers (legal entities) to obtain a zero withholding tax
rate from KDPW shall be:
a) Taxpayer disclosure,
b) Submission of a U106 declaration, in instances where the Taxpayer holds the status of
qualified holder,
c) The ability for KDPW to determine on the basis of disclosure by the Taxpayer that it is a Polish
Investment Fund or a Polish Pension Fund, which is entitled to the tax exemption.
3. Disclosure of the Taxpayer consists of the omnibus securities account holder submitting the
Taxpayer’s details to KDPW within the set deadline (see Table 1), separately for each corporate
event. This is performed using an electronic message template. The scope of disclosed personal
details is derived from Polish tax regulations, which define disclosure obligations for KDPW in its
role as withholding agent for income tax.
4. In all remaining instances, as well as in instances, where the CIT Taxpayer remains undisclosed,
KDPW in its role of withholding agent shall withhold tax according to the standard CIT rate (19) for
income from payments of dividends and other cash distributions relating to shares in corporate
profits.
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
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PROCESSING OF POLISH RESIDENTS BEING PIT TAXPAYERS (NATURAL PERSONS) – STANDARD PIT
TAX RATE
KDPW withholds tax on income at a standard flat rate of 19% from Polish Residents being PIT
Taxpayers (natural persons), irrespective of whether the Taxpayer has been disclosed by the holder
of the omnibus securities account.
PROCESSING OF UNDISCLOSED TAXPAYERS – STANDARD TAX RATE
KDPW withholds a flat rate of tax on income derived from dividends and other cash distributions
relating to shares in corporate profits, according to the standard rate of 19% applicable for
undisclosed CIT Taxpayers (legal entities), or undisclosed PIT Taxpayers (natural persons).
4. Tax Quick Refund for equities – processing of withheld tax prior to remittance to relevant Tax
Office
Chart 2: Quick Refund – tax breakdown for income from payments of dividends and other cash
distributions relating to shares in corporate profits
Possible change from PIT to
CIT and from CIT to PIT tax
groups
Possible change from PIT to CIT tax group
Taxpayers qualified to tax groups as for Relief at Source
Non-Resident
PIT/CIT Taxpayer
Non-Resident
CIT Taxpayer
PL Resident
CIT Taxpayer
Certificate of Residence
Tax Declaration U107 (DTT)
Tax Declaration U101, U102,
U106 or other specific
Tax Declaration
U106
BO Disclosure
19% minus DTT tax rate
Full refund (19%)
1. As part of the Quick Refund procedure, KDPW enables tax withheld as part of the Relief at Source
procedure on a cash payment to be refunded, in the period after the tax on derived income has
been withheld and before the date of the remittance of the tax to the tax office.
2. The Quick Refund procedure starts after the date of the cash payment event at Relief at Source.
The deadline for submitting the required documents (Table 2) is the second working day of the
month following the month in which the cash payment took place.
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
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3. The list of documents and instructions submitted to KDPW will be the same as for processing of
Relief at Source.
4. The payment resulting from the QR process is made exclusively in PLN, regardless of the currency
in which the payment was made by the issuer.
5. The Quick Refund service envisages the ability to correct the allocation between Taxpayer status
groups (i.e. to amend the tax breakdown between CIT Taxpayers and PIT Taxpayers) by the holder
of the omnibus securities account. Authorised corrections may only be permitted between
Taxpayers in a higher tax group being re-allocated to a lower tax group or between groups of
Taxpayers to which an identical tax rate is applied, always subject to the condition that the
Taxpayer causing the correction, shall be disclosed.
Table 2: Deadline for submitting information to KDPW related to Quick Refund processing
Submission of information
Deadline
Equities
The second business day following the month of the
Issuer’s payment
This material has been prepared for informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting
advice.While every effort has been made to ensure that the information in this material is correct, KDPW S.A cannot be held liable for any claims or losses of any
nature arising from any use by any person of information contained herein.
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