Poland’s Beneficial-Owner Guidance Is Too Broad, Group Says

Poland’s draft guidance on applying beneficial ownership in the context of the country’s updated tax withholding rules takes an “overly broad” view, and pushes it into areas where it may not be appropriate, a business group said Tuesday.

The guidance seems to impute beneficial ownership into a wide variety of tax treaties and directors, the National Foreign Trade Council said in a comment letter—even when language regarding the concept wasn’t included when a treaty was negotiated. Forcing it in amounts to unilaterally amending a treaty, the NFTC said.

Moreover, the group said, the draft provides for applying Poland’s domestic ...