Poland: Protocol to tax treaty with the Netherlands
Poland and the Netherlands signed a Protocol to amend the existing income tax treaty between the two countries.
Protocol to tax treaty with the Netherlands
Representatives of the governments of Poland and the Netherlands on 29 October 2021 signed a Protocol to amend the existing income tax treaty between the two countries.
The Protocol includes measures regarding the taxation of real estate, the definition of a permanent establishment, and “recognized” pension funds.
The Protocol also clarifies the tax treatment of an entity or arrangement that is wholly or partially tax transparent.
Each country must ratify the Protocol, and it is expected that the provisions under the Protocol would be effective no earlier than 1 January 2023 (assuming the Netherlands ratifies the Protocol by the end of September 2022).
Read a December 2021 report prepared by the KPMG member firm in Poland
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.