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

 

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