The Polish government has postponed the implementation of restrictions on cross-border dividends, interest, and royalty payments.

The restrictions were to be introduced January 1, 2019. Two draft Ministry of Finance ordinances, dated December 7, delay the application of the restrictions until June 30, 2019, for cross-border royalties and interest payments and until December 31, 2019, for cross-border dividend payments. Both ordinances will enter into force January 1, 2019.

The restrictions, which apply to both personal income and corporate income tax, were introduced by a law dated October 23 and published November 23.

Janusz Fiszer, partner, GESSEL Attorneys at Law, Warsaw, and associate professor, School of Management at the University of Warsaw.