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New Cyprus - Poland Double Tax Treaty Protocol
Wednesday, March 28, 2012
 

 

The new Protocol amending the Double Tax Treaty between Cyprus and Poland was signed by representatives of the two states on 22 March 2012. The amended treaty will come into effect on 1 January following the year in which ratification takes place.

The main changes are highlighted below:

• The withholding tax rate on dividends has been reduced from 10% to 0% if the shareholder company owns at least 10% of the share capital of the company distributing the dividends and 5% in all other cases;

• The withholding tax rate on interest has been reduced from 10% to 5%;

• The withholding tax rate on the royalties remains the same at 5%. The definition of the term royalties has also be re-defined to be aligned with the OECD Model Treaty;

• Director fees earned by an individual will only be taxable in the State in which the individual is a resident;

• Tax sparing credits will no longer be given i.e. tax credits which would have been given by one State for taxes that should have been payable in the other State but were spared by the other State; and

• Lastly, the new exchange of information article has been adopted, which is in line with the article in the OECD Model Treaty.

Our tax department is ready to assist you with queries or clarifications you may require at info@istosglobal.com


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