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Protocol to Tax Treaty between Poland and South Korea to Enter into Force

According to an update from the Polish Ministry of Finance, the protocol to the 1991 income tax treaty with South Korea will enter into force on 15 October 2016. The protocol, signed 22 October 2013, is the first to amend the treaty, and includes the following changes:

  • Article 2 (Taxes Covered) is updated so that the treaty covers Korean income tax, corporation tax, the special tax for rural development, and local income tax, and covers Polish personal income tax and corporate income tax;
  • The term "competent authority" under Article 3 (General Definitions) is updated for each country;
  • Paragraph 3 of Article 8 (Shipping and Air Transport) concerning an exemption from VAT or similar tax for the operation of ships or aircraft in international traffic is deleted;
  • Article 9 (Associated Enterprises) is replaced/updated;
  • Article 11 (Interest) is updated in regard to the government owned banks for which a withholding tax exemption on interest applies;
  • Article 12 (Royalties) is amended to reduce the withholding tax rate for royalties from 10% to 5% and to update the definition of royalties;
  • Article 13 (Capital Gains) is amended to provide that gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State;
  • Article 22A (Limitation on Benefits) is added, and stipulates that for Articles 10 (Dividends), 11 (Interest), 12 (Royalties), 13 (Capital Gains), and 22 (Other Income), a resident of a Contracting State will not be entitled to benefits of the treaty if the main purpose or one of the main purposes of any person concerned with the creation or assignment of a share, a debt-claim, or a right in respect of which the income is paid is to take advantage of these Articles by means of that creation or assignment;
  • Article 23 (Relief from Double Taxation) is replaced with both countries continuing to apply the credit method, but also providing a credit for the tax payable on the profits out of which the dividends are paid, subject to certain conditions; and
  • Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standard for information exchange.

The protocol generally applies from 1 January 2017. However, the new Article 26 (Exchange of Information) applies from 1 January 2014.

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