11 Sep Article Of Double Taxation Agreement Poland
Unlike the current OECD Model Agreement, the Agreement establishes rules for independent personal services. On 21 October 2016, Poland and Taiwan signed a special double taxation convention («the Convention»). As these are 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. With regard to capital gains, the agreement contains a clause on companies rich in immovable property which provides that profits generated by a territory located in one territory may be taxed in that other area from shares derived directly or indirectly from immovable property located in the other zone, which derive more than 50% of their value from real estate located in the other zone. The agreement follows the OECD Model Agreement, 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 the tax legislation administered by the Polish Ministry of Finance or taxes in the territory where the tax legislation administered by the Ministry of Finance of Taiwan is applied. The same references are used to define the term «territory» and are followed throughout the agreement. The definition of the term «permanent establishment» follows the standard language of the OECD Agreement, as defined in the Convention, one after the other, the construction site, construction or installation project constituting a permanent establishment only if it lasts more than 12 months. Both territories apply a regular credit as a method of avoiding double taxation of income. The agreement also contains a specific provision on the limitation of benefits.
The Double Taxation Convention entered into force on 27 December 2006. According to the agreement, withholding taxes on cross-border dividends and interest payments are limited to 10% of gross amounts, while withholding taxes on cross-border license payments are limited to 3% when royalties are paid in return for the use or right of use. industrial, commercial or scientific equipment and, in all other cases, 10% of the gross amount of royalties. On 15 December 2016, the Polish Parliament adopted a special law on principles for the avoidance of double taxation of income between the two above-mentioned areas, which effectively allows the implementation of the Convention. As a result, the agreement entered into force on 1 January 2017 and applies to income received on or after that date. The provisions of the MLI entered into force on 1 the text of the multilateral instrument and the 2006 double taxation convention between Poland and the United Kingdom was added. This file may not be suitable for users of ancillary technologies. . The 2006 Poland-United Kingdom Double Taxation Convention has been amended by the Multilateral Instrument (MLI).
Tax treaties and related documents between the United Kingdom and Poland. It is in force in Poland from 1 January 2007 and in Great Britain. . . .