Abstract

Th e subject of this article is taxation of transboundary dividend money for partnership on the grounds of bilateral contracts in a situation of so-called qualifi cation confl icts. Th rough the rule introduced by the Polish legislator on binding Poland with a qualifi cation eff ectuated by the state, the risk of qualifi cation confl icts has been limited. In the article there is a presentation of examples of qualifi cation confl icts which still may appear in a situation where the entity paying dividends is Polish LLC.