Article Of Double Taxation Agreement Poland

3 12 2020

On 15 December 2016, the Polish parliament adopted a specific law on principles aimed at avoiding double taxation of income between the two aforementioned regions, which enabled the effective implementation of the agreement. As a result, the agreement came into effect on January 1, 2017 and applies to income collected on or after that date. With respect to capital gains, the agreement contains a clause relating to a wealth corporation which provides that the profits generated by the disposal of shares directly or indirectly derived from more than 50% of their value of real estate located in the other territory may be taxed in that other region. Under the agreement, withholding tax on cross-border dividends and interest payments are limited to 10% of gross amounts, while withholding tax on cross-border royalties is limited to 3% for royalties paid in return for use or right to use, commercial, commercial or scientific equipment and 10% of gross royalties in all other cases. The Double Taxation Agreement came into force on December 27, 2006. Unlike the current OECD model convention, the agreement provides rules for independent personal services. Both contractual areas apply a regular credit as a means of avoiding double taxation of income. The agreement also contains a specific forecast for the limitation of benefits. On 21 October 2016, Poland and Taiwan signed a special double taxation agreement (“the agreement”).

Since this is not diplomatic relations between Poland and Taiwan, the agreement was officially concluded between the Warsaw Trade Office in Taipei and the Taipei Economic and Cultural Office in Warsaw. The agreement follows the OECD model convention, with a number of important derogations. With regard to the description of the taxes recorded, the agreement covers taxes in the area of application of tax legislation managed by the Polish Ministry of Finance and on taxes in the area where the tax legislation managed by the Ministry of Finance, namely Taiwan, applies. The same references are used for the definition of “territory” and are respected throughout the agreement. The definition of establishment is the standard language of the OECD agreement, provided that the construction, construction or installation project is only a stable facility if it lasts more than 12 months. Tax treaties and related documents between the UK and Poland. . The 2006 double taxation convention between Poland and the United Kingdom was amended by the Multilateral Instrument (MLI). The summary text of the multilateral instrument and the 2006 convention between Poland and the United Kingdom on double taxation has been added.