Poland: Tax Treaties

Tax Treaties

Dividends are generally subject to a 19% rate, which can be reduced under a DTA (of which Poland has more than 80), and is removed altogether when paid to companies in EU and EEA states, subject to the conditions of the Parent-Subsidiary Directive.

Poland additionally benefits from a transitional period for removing the withholding tax on interest and royalty payments paid by Polish corporate residents to associated EU companies. From 1 July 2009, it is 5% (previously 10%). From 1 July 2013, the full exemption will be in place.

Where there are no special rules in place, withholding taxes are imposed under the general provisions of the Corporate Income Tax Act, and the applicable Double Tax Treaty, if there is one in place (Poland has, at the time of writing, more than 80 such agreements in place).

Below are the withholding tax rates as provided in the treaties concluded by Poland with some of its main trading partners at the time of writing. However, the table below only shows rates, which result from general Treaty provisions. The Treaties themselves sometimes include special provisions (applicable in special circumstances or to special entities) providing for rates that are lower than those listed below:

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