Certain new treaties for the avoidance of double taxation have come into force between Poland and the following countries:
  • Ireland
  • the Republic of Croatia
  • the Republic of Slovakia
  • the Republic of South Africa.
Some interesting possibilities exist on the basis of the Treaty between Poland and Ireland, including:
  • 15% withholding rate on dividends. However, dividends paid out to a Polish resident company are tax exempt in Ireland (and vice versa) where 25% of the voting power in the company paying out the dividends is held;
  • withholding tax on interest payments limited to 10% of gross interest;
  • withholding tax on royalty payments is limited to 10% of gross interest;
  • branch activities of a Polish entity in Ireland should be exempt from further taxation in Poland. This means that for example an entity engaged in manufacturing or, under certain conditions, financial services would only be subject to 10% corporate tax in Ireland.
It should also be noted that the treaty between Poland and Denmark has been updated and now under certain circumstances includes no Danish tax liability for Danish companies which receive dividends from certain Polish companies in which they hold at least 25% of shares. The update has been backdated to 1992 in Denmark.

this information was correct as of 11 September 1997.

Tax laws and practise are constantly being revised and, whilst every effort is made to ensure that the information in this tax newsletter is accurate and timely, no decision should be taken on the basis of the information herein without first consulting with KPMG Polska.

Should you have any questions in relation to the above issues, please contact:
Oliver Sinton
KPMG Polska
LIM Center - Marriott Hotel - IX floor
Al. Jerozolimskie 65/79
00-697 Warsaw, Poland
Tel: +48 (22) 630 7236
Fax: +48 (22) 630 6355