Bond issues under EMTN Programme
Tax information
INFORMATION ON ART. 26 PARA. 1AE of the CITA[i] FOR RELATED ENTITIES [ii] ON THE CONDITIONS FOR EXEMPTION of income from interest or discount on bonds earned by a taxpayer who does not have a registered office or management in the territory of the Republic of Poland and who is subject to taxation only on income which he earns in the territory of the Republic of Poland.
PKO Bank Polski S.A. (hereinafter: "Issuer"), as the issuer of the bond issues indicated below, hereby informs that pursuant to Art. 17, section 1, item 50c) of the CITA, income earned by a taxpayer referred to in Art. 3, section 2 of the CITA from interest or discount on bonds is tax-free:
- have a maturity of no shorter than 1 year;
- have been admitted to trading on a regulated market or introduced to an alternative trading system within the meaning of the Act on Trading in Financial Instruments of 29 July 2005, in the territory of the Republic of Poland or a state which has signed a double taxation treaty with the Republic of Poland whose provisions define the principles for taxation of dividend and interest income and income from licence receivables;
- unless as at the moment of earning the income the taxpayer is, within the meaning of Article 11a (1) (4) of the CIT Act or within the meaning of Article 23m (1) (4) of the Personal Income Tax Act of 26 July 1991, a related entity of the issuer of such bonds and holds, jointly with the other related entities within the meaning of the above-mentioned regulations, more than 10% of the nominal value of such bonds;
The Issuer would also like to point out that detailed withholding tax exemption requirements are described in Prospectuses of PKO Bank Polski S.A. in accordance with which the bonds referred to below were issued.
The Issuer provides the above information with respect to the following bond issues: | ||||
| No. | ISIN | Nominal value of the issuance | Issuance date | Maturity date |
| 1. | PLPKO0000099 | 1 700 000 000 PLN | 2017-08-28 | 2027-08-28 |
| 2. | PLPKO0000107 | 1 000 000 000 PLN | 2018-03-05 | 2028-03-06 |
| 3. | XS2582358789 | 750 000 000 EUR | 2023-02-01 | 2026-02-01 |
| 4. | PLO046700012 | 1 000 000 000 PLN | 2024-02-28 | 2029-02-28 |
| 5. | XS2788380306 | 500 000 000 EUR | 2024-03-27 | 2028-03-27 |
| 6. | XS2842080488 | 500 000 000 EUR | 2024-06-18 | 2029-06-18 |
| 7. | XS2890435865 | 750 000 000 EUR | 2024-09-12 | 2027-09-12 |
| 8. | PLO046700020 | 1 500 000 000 PLN | 2024-10-16 | 2034-10-16 |
[i] Corporate Income Tax Act of 15 February 1992
[ii] Entities affiliated with PKO Bank Polski S.A. within the meaning of art. 11a par. 1 pt. 4 of the Act of 15 February 1992 on Corporate Income Tax or within the meaning of art. 23m par. 1 pt. 4 of the Act of 26 July 1991 on Income Tax from Natural Persons, excluding entities whose links arise exclusively from relations with the State Treasury or local government units or their associations.
Past issues
