Poland: Multilateral convention implementing BEPS; effects on Poland's tax treaties

Poland: Multilateral convention implementing BEPS

The Ministry of Finance has not released any official guidance on the scope of the planned amendments to Poland's network of income tax treaties in advance of the scheduled signing on 7 June 2017 of the multilateral convention for implementing measures in the OECD's base erosion and profit shifting (BEPS) Action 15.

1000

Related content

The amendments to be introduced by the multilateral convention concern four main areas:

  • Preventing the use of hybrid mismatch arrangements
  • Preventing the granting of tax benefits in inappropriate circumstances
  • Preventing the avoidance of permanent establishment (PE) status that may artificially eliminate the prerequisites for creation of a PE in light of existing tax treaties
  • Improving the dispute resolution mechanisms available in the tax treaties, including the mutual agreement procedure (MAP)

In Poland, the publication of information about the effects on Poland’s tax treaties affected by the multilateral convention are expected no earlier than after the official signing ceremony on 7 June 2017. It is expected that ratification of the convention by Poland would significantly affect the income tax treaty provisions, and that modifications to the treaties could be expected.

 

Read a June 2017 report [PDF 385 KB] prepared by the KPMG member firm in Poland

© 2017 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Request for proposal

 

Submit

KPMG's new digital platform

KPMG International has created a state of the art digital platform that enhances your experience, optimized to discover new and related content.