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Polish tax residents (both legal entities and natural persons) are liable for CIT and personal income tax (PIT) on the profits earned by their controlled foreign companies (CFC), even if the income is not distributed by the CFC. Apart from legal persons and organizational units without legal ...
then foreign partnerships themselves must qualify for DTA benefits for any relief to be available. This means that the partnerships need to show that they have registered with foreign tax authorities as tax residents and have paid tax as residents. One cannot just look through...