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Poland: Double Tax Treaties

Table Of Treaty Rates

Provided by TreatyPro
Poland


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 19% 20% 20%
           
Albania Effective January 1, 1995 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 10% 5%
Algeria Signed January 31, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid by the government, or to the government or the central bank, or on financing approved by both governments 10% 10% Not yet in force. Default rates apply.
Armenia Effective January 1, 2006 10% 5% 10%
Australia Effective January 1, 1993 15% 10% 10%
Austria Effective January 1, 2006 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on a bank loan, or on a loan financed, guaranteed or insured by an institution to promote exports, or on sales on credit of equipment 5% 5%
Azerbaijan Effective January 1, 2006 10% 0% when paid to the government or the central bank 10% 10%
Bangladesh Effective January 1, 2000 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government or the central bank 10% 10%
Belarus Effective January 1, 1994 10% where the payee is a company holding directly at least 30% of the paying company's capital 15% 0% when paid because of a transaction approved by Poland 10% 0%
Belgium Effective January 1, 2005 5% where the payee is a company (excluding a partnership) either holding directly at least 25% of the paying company's capital, or holding directly at least 10% of the paying company's capital with a value of at least EUR500,000 or equivalent 15% 0% when paid to the government, or on a bank loan not represented by bearer instruments, or on a loan or credit financed, guaranteed or insured to promote exports 5% 5%
Bosnia and Herzegovina Effective January 1, 1985 New treaty signed June 4, 2014 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% When new treaty is effective: 0% when paid to the government or the central bank 10% 10% New treaty not yet in force.
Bulgaria Effective January 1, 1996 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 5%
Canada Effective January 1, 2014 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services 10% 5% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Chile Effective January 1, 2004 5% where the payee is a company holding directly at least 20% of the paying company's voting stock 15% 15% 5% for equipment royalties 15%
China Effective January 1, 1990 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 7% for equipment royalties 10%
Croatia Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 10%
Cyprus Effective January 1, 1992 Protocol effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 5% 0% when paid to the government or the central bank, or on a loan or credit financed or guaranteed by the government or the central bank 5% 5%
Czech Republic Effective January 1, 2013 5% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government or the central bank, or on a bank loan or credit 5% 10%
Denmark Effective January 1, 2003 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital for 12 months before the dividend is declared 5% if paid to a pension fund 15% 0% when paid to the government, or on government bonds or debentures, or on a loan financed, guaranteed or insured by the government, or on sales on credit of equipment 5% 5%
Egypt Effective January 1, 2002 12% 0% when paid to the government or the central bank 12% 12%
Estonia Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Finland Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by a specified institution to promote exports, or on a bank loan, or on sales on credit of equipment 5% 5%
France Effective January 1, 1974 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% 0% for copyright royalties (excluding broadcasting royalties) 10%
Georgia Effective January 1, 2007 10% 0% when paid to the government or the central bank 8% 8%
Germany Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government, or on a loan financed, guaranteed or insured by an institution to promote exports, or on a bank loan, or on sales on credit of equipment or goods 5% 5%
Greece Effective January 1, 1992 19% (3) 10% 10%
Hungary Effective January 1, 1996 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Iceland Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
India Effective January 1, 1990 Protocol effective January 1, 2015 10% 0% when paid to the government or the central bank, or on a loan or credit extended or endorsed by a specified institution in respect of imports or exports, or on a government approved loan or credit 10% 15%
Indonesia Effective January 1, 1994 10% where the payee is a company holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 15%
Iran Effective January 1, 2007 7% 0% when paid to the government or the central bank 10% 10%
Ireland Effective January 1, 1996 0% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% 0% when paid on a bank loan, or on sales on credit of equipment or merchandise 10% 10%
Israel Effective January 1, 1992 5% where the payee is a company holding directly at least 15% of the paying company's capital 10% 5% 5% for equipment royalties 10%
Italy Effective January 1, 1984 10% 0% when paid to or by the government, or on a loan approved by both governments 10% 10%
Japan Effective January 1, 1982 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or indirectly financed by the government or the central bank 10% 0% for copyright or broadcasting royalties 10%
Jordan Effective January 1, 2000 10% 0% when paid to the government or the central bank 10% 10%
Kazakhstan Effective January 1, 2000 10% where the payee is a company holding at least 20% of the paying company's capital 15% 0% when paid to the government 10% 10%
Korea, South Effective January 1, 1991 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit financed or guaranteed by a specified institution, or on sales on credit of equipment or merchandise 10% 10%
Kuwait Effective January 1, 1996 0% where the payee is the government or the central bank, or a company at least 25% owned by the government or the central bank 5% 0% when paid to the government or the central bank, or to a company at least 25% owned by the government or the central bank, or on a loan guaranteed by the government or the central bank 5% 15%
Kyrgyzstan Effective September 1, 2004 10% 0% when paid to the government or the central bank 10% 10%
Latvia Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Lebanon Effective January 1, 2004 5% 0% when paid to the government, or on a loan or credit financed or insured by the government 5% 5%
Lithuania Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Luxembourg Effective January 1, 1997 Protocol effective September 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 15% 0% when paid to the government, or on a bank loan or credit 5% 5%
Macedonia Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Malaysia Effective January 1, 1977 New treaty signed July 8, 2013 0% When new treaty is effective: 5% 15% When new treaty is effective: 0% when paid to the government or the central bank, or on a government loan or credit 10% 15% 20% for broadcasting royalties (3) When new treaty is effective: 8% New treaty not yet in force.
Malta Effective January 1, 1995 Protocol effective January 1, 2012 0% where the payee is a company holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 10% 0% when paid to the government or the central bank 5% 5%
Mexico Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to or by the government or the central bank, or to a pension fund, or on a loan or credit financed, guaranteed or insured for at least three years by a specified institution 5% when paid to a bank or insurance company, or on bonds or securities regularly traded on a recognised securities market 15% 10%
Moldova Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the government 10% 10%
Mongolia Effective January 1, 2002 10% 0% when paid to the government or the central bank, or on a loan or credit indirectly financed by the government or the central bank 10% 5%
Morocco Effective January 1, 1996 7% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%
Netherlands Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, or on government bonds or debentures, or on a bank loan, or on a loan financed, guaranteed or insured by an institution to promote exports, or on sales on credit of equipment 5% 5%
New Zealand Effective January 1, 2007 15% 10% 10%
Nigeria Signed February 12, 1999 10% 0% when paid to the government 10% 10% Not yet in force. Default rates apply.
Norway Effective January 1, 2011 0% where the payee is a company holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 15% 0% when paid to the government or the central bank, or on a bank loan, or on a loan financed, guaranteed or insured by an institution to promote exports, or on sales on credit of equipment 5% 5%
Pakistan Effective January 1, 1973 15% where the payee is a company holding at least 33% of the paying company's capital 19% (3) 0% when paid to the central bank 20% (3) 15% for the use of any information concerning industrial, commercial or scientific experience 20%
Philippines Effective January 1, 1998 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by the central bank 10% 15%
Portugal Effective January 1, 1999 10% where the payee is a company holding directly at least 25% of the paying company's capital for 24 months before payment of the dividend 15% 0% when paid to or by the government, or on a loan or credit financed by the central bank, or on financing approved by both governments 10% 10%
Qatar Effective January 1, 2010 5% 0% when paid to the government, or on a bank loan, or on a loan financed, guaranteed or insured by an institution to promote exports, or on sales on credit of equipment 5% 5%
Romania Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Russia Effective January 1, 1994 10% 0% when paid to the government or the central bank 10% 10%
Saudi Arabia Effective January 1, 2013 5% 0% when paid by the government, or to the government or the central bank 5% 10%
Montenegro Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%
Singapore Effective January 1, 2015 0% when paid to the government or the central bank 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 10% 0% when paid by the government, or to the government or the central bank 5% 2% for equipment royalties 5%
Slovakia Effective January 1, 1996 Protocol effective January 1, 2015 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend 5% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 5% 5%
Slovenia Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
South Africa Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Spain Effective January 1, 1983 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10%
Sri Lanka Effective January 1, 1983 15% 0% when paid to the government or a bank 10% 0% for copyright or broadcasting royalties 10%
Sweden Effective January 1, 2006 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 5%
Switzerland Effective January 1, 1992 Protocol effective July 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend, or a pension fund 15% 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 5% 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 5%
Syria Effective January 1, 2004 10% 0% when paid by the government, or to the government or the central bank, or on a loan or credit guaranteed or insured by the government 10% 18%
Tajikistan Effective September 1, 2004 5% where the payee is a company (excluding a partnership) holding at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
Thailand Effective January 1, 1984 19% (4) 0% when paid to the government or the central bank 10% when paid to a financial institution or insurance company 20% (3) 0% for broadcasting royalties paid to the government 5% for copyright royalties (excluding broadcasting royalties) 15%
Tunisia Effective January 1, 1994 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 12% 12%
Turkey Effective January 1, 1998 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan supported by the government 20% 10%
Ukraine Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding at least 25% of the paying company's capital 15% 0% when paid to the government 10% 10%
United Arab Emirates Effective January 1, 1995 0% where the payee is the government or a company at least 25% owned by the government 5% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 5% 5%
United Kingdom Effective January 1, 2007 0% where the payee is a company holding at least 10% of the paying company's capital for 24 months before payment of the dividend 10% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by a government institution to promote exports, or on a bank loan, or on sales on credit of equipment 5% 5%
United States Effective January 1, 1974 New treaty signed February 13, 2013 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% When new treaty is effective: 0% when paid to a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 0% When new treaty is effective: 0% when paid by the government or the central bank, or to the government, the central bank, a pension fund, a bank, an insurance company or a financial institution, or on a loan or credit financed, guaranteed or insured by the government 5% 10% When new treaty is effective: 5% New treaty not yet in force.
Uruguay Signed August 2, 1999 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 15% 15% Not yet in force. Default rates apply.
Uzbekistan Effective January 1, 1996 5% where the payee is a company holding at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
Vietnam Effective January 1, 1996 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10% for the use of any patent, design or model, plan, secret formula or process, or information concerning industrial or scientific experience 15%
Zambia Signed May 19, 1995 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10% Not yet in force. Default rates apply.
Zimbabwe Effective January 1, 1995 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%
Serbia Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest and royalties withholding tax to 5%, subject to certain conditions.
  3. The domestic rate applies.
  4. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  5. PLEASE NOTE: This table was last updated February 2015

 

 

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