Proceedings regarding withholdig tax on dividends paid by Polish companies to Switzerland in 2011

Dividends paid by Polish companies to related entities based in Switzerland have generally benefited from exemption from withholding tax (tax at source) in recent years (provided that a Swiss entity held no less than 25% of the share capital of the company paying the dividend). There has been only one doubt about dividend payments made in 2011 because of an amendment to the CIT Act and the terms of the Poland-Switzerland convention on the avoidance of double taxation.