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In the case of a deduction from CIT for payment in Poland of withholding tax paid in Brazil, to specify the amount of the deduction, the applicant should consider the date of payment of the tax as the date of the transfer by the payer in the local currency to the account of the local tax authority. As a result, the applicant should use the average exchange rate of the Brazilian real, announced by the National Bank of Poland, on the last business day preceding the day of the transfer by the payer.

KIS interpretation of 17/03/2022 (0111-KDIB1-2.4010.681.2021.1.AK).