Poland: Multilateral convention implementing BEPS | KPMG Global
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Poland: Multilateral convention implementing BEPS; effects on Poland's tax treaties

Poland: Multilateral convention implementing BEPS

The Ministry of Finance has not released any official guidance on the scope of the planned amendments to Poland's network of income tax treaties in advance of the scheduled signing on 7 June 2017 of the multilateral convention for implementing measures in the OECD's base erosion and profit shifting (BEPS) Action 15.


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The amendments to be introduced by the multilateral convention concern four main areas:

  • Preventing the use of hybrid mismatch arrangements
  • Preventing the granting of tax benefits in inappropriate circumstances
  • Preventing the avoidance of permanent establishment (PE) status that may artificially eliminate the prerequisites for creation of a PE in light of existing tax treaties
  • Improving the dispute resolution mechanisms available in the tax treaties, including the mutual agreement procedure (MAP)

In Poland, the publication of information about the effects on Poland’s tax treaties affected by the multilateral convention are expected no earlier than after the official signing ceremony on 7 June 2017. It is expected that ratification of the convention by Poland would significantly affect the income tax treaty provisions, and that modifications to the treaties could be expected.


Read a June 2017 report [PDF 385 KB] prepared by the KPMG member firm in Poland

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