(Archived Content)
Warsaw—The U.S. Department of the Treasury announced today that Ambassador Stephen Mull and Polish Deputy Finance Minister Maciej Grabowski signed a new income tax treaty between the United States and Poland.
In a ceremony held at the Polish Ministry of Finance in Warsaw today, the two officials signed a new tax treaty that would replace the existing agreement, signed in 1974, and bring the bilateral relationship into closer conformity with current U.S. tax treaty policy. Significantly, the new treaty contains a comprehensive limitation on benefits provision that is consistent with many recently concluded U.S. tax treaties, and that is intended to ensure that only residents of the United States and Poland will enjoy the benefits of the treaty.
The new treaty provides for reductions in withholding taxes on cross-border payments of dividends, interest and royalties. The new treaty also incorporates new methods for attributing business profits to a permanent establishment. The new methods were recently developed by the Organization for Economic Cooperation and Development and are consistent with U.S. tax treaty policy.
Consistent with U.S. tax treaty policy and the international standard for tax information exchange, the new treaty provides for the full exchange of information between the competent authorities to facilitate the administration of each country’s tax laws.
The text of the treaty document can be found at: http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/Treaty-Poland-2-13-2013.pdf.
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