On 20 April 2010, Switzerland and Poland signed an amending protocol to the income and capital tax treaty of 2 September 1991.
The maximum rates of withholding tax are:
|-||15% on dividends, with and an exemption from tax if the beneficial owner is (i) a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends for an uniterrupted 24-month period; or (ii) a pension fund which is established, recognized for tax purposes and controlled by the laws of the other contracting state.|
|-||5% on interest and royalties, with an exemption if the beneficial owner is an associated corporation (other than a partnership).|
Gains derived from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in the source state may be taxed in that source state.
There are also provisions for mutual agreement procedure and exchange of information.
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