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Poland Publishes Synthesized Text of Tax Treaties with Finland and Ireland as Impacted by the BEPS MLI

Poland's Ministry of Finance has published the synthesized texts of the 2009 tax treaty with Finland and the 1995 tax treaty with Ireland as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The texts constitute auxiliary tools only, aimed at documenting the impact of the MLI to the respective treaties and do not constitute a source of law. As provided in the synthesized texts, the MLI applies:

  • For the 2009 Finland-Poland tax treaty:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes levied by Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2020; and
  • with respect to all other taxes levied by Poland, for taxes levied with respect to taxable periods beginning on or after 1 December 2019;
  • For the 1995 Ireland-Poland tax treaty:
  • with respect to taxes withheld at source on amounts paid or credited to nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes levied by Ireland and Poland, for taxes levied with respect to taxable periods beginning on or after 1 November 2019; and
  • with respect to modifications made to Article 26 (Mutual Agreement Procedure) by MLI Article 16, for a case presented on or after 1 May 2019, except for cases that were not eligible to be presented as of that date under the Agreement prior to its modification by the MLI.

Click the following link for the Ministry of Finance treaty webpage that includes the synthesized texts of Poland's treaties, including both Polish and English-language versions.

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