Changes to the Polish-Cypriot tax treaty have been negotiated by
the Polish Ministry of Finance.
Details of the changes have not been officially released, however,
the Ministry of Finance has indicated informally that the key
changes relate to:
- the removal of the 'tax sparing' clause which made it possible to decrease the effective tax rate on dividends paid by a Cypriot company to its Polish shareholders from 19% to 9% through the deduction from the tax in Poland (19%) an amount equal to the tax which is payable (even if not paid due to exemption) in Cyprus (10%);
- taxation of income of directors of Cypriot companies who are Polish tax residents
- up to now, it was not subject to taxation, either in Cyprus or
in Poland.
It is not yet known when the changes will take effect. Unofficial
information suggests that this may be 1 January 2012 or 1 January
2013.
This article was written for Law-Now, CMS Cameron McKenna's free online information service. To register for Law-Now, please go to www.law-now.com/law-now/mondaq
Law-Now information is for general purposes and guidance only. The information and opinions expressed in all Law-Now articles are not necessarily comprehensive and do not purport to give professional or legal advice. All Law-Now information relates to circumstances prevailing at the date of its original publication and may not have been updated to reflect subsequent developments.
The original publication date for this article was 23/08/2011.
