• Cyprus - Poland
    Provisions of Amending Protocol Come Into Effect

    04-01-2013

    The provisions of the amending Protocol to the tax treaty between Cyprus and Poland came into effect on 1 January 2013.

    In accordance with the amending protocol, the following withholding tax rates will apply:

    • Dividends:
      • 0% if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of 24 months.
      • 5% in all other cases.

    • Interest: 5% withholding tax on interest.

    • Royalties: 5% withholding tax on royalties.

    On 15 August 2012, Poland ratified the amending protocol to the existing tax treaty with Cyprus.

    Cyprus has already ratified the amending protocol and therefore the new provisions of the tax treaty are expected to apply from 1 January 2013.

    In accordance with the amending protocol, the following withholding tax rates will apply:

    • Dividends:
      • 0% if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of 24 months.
      • 5% in all other cases.

    • Interest: 5% withholding tax on interest.

    • Royalties: 5% withholding tax on royalties.
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