Poland: Protocol to income tax treaty with the Netherlands scheduled to enter into force

The Protocol is set to enter into force 30 April 2022.

The Protocol is set to enter into force 30 April 2022.

A Protocol (signed 29 October 2020) amending the income tax treaty between Poland and the Netherlands has been advanced by both signatory countries—Poland having completed its ratification process in 2021 and the Netherlands in March 2022.

Accordingly, the Protocol is set to enter into force 30 April 2022 and apply to tax years, tax periods, and taxable events occurring from 1 January 2023. Read TaxNewsFlash

The Protocol includes measures:

  • Supplementing the treaty’s provisions regarding the taxation of real estate
  • Introducing a solution commonly referred to as the “principal purpose test”
  • Amending the definition of a permanent establishment
  • Introducing the concept of “recognized” pension funds

Read a March 2022 report prepared by the KPMG member firm in Poland


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