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.
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
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.