HMRC has published the ‘synthesised’ text of the UK’s double taxation convention with Poland, as modified by the BEPS multilateral instrument (MLI). The MLI came into force for the UK on 1 October 2018 and for Poland on 1 July 2018.
The MLI modifies the 2006 Poland/UK double tax convention and is effective from:
1 January 2019 for taxes withheld at source;
1 April 2019 for corporation tax;
6 April 2019 for income tax and CGT; and
1 April 2019 for all other taxes levied by Poland for taxable periods beginning on or after that date.
The MLI allows jurisdictions to integrate elements of the OECD/G20 BEPS project into their existing bilateral tax treaties. In July, HMRC published the final list of UK reservations and notifications for the UK’s ‘covered tax agreements’ under the MLI.
The authentic legal texts of the 2006 double tax convention and the MLI take precedence and remain the legal texts applicable.
HMRC has published the ‘synthesised’ text of the UK’s double taxation convention with Poland, as modified by the BEPS multilateral instrument (MLI). The MLI came into force for the UK on 1 October 2018 and for Poland on 1 July 2018.
The MLI modifies the 2006 Poland/UK double tax convention and is effective from:
1 January 2019 for taxes withheld at source;
1 April 2019 for corporation tax;
6 April 2019 for income tax and CGT; and
1 April 2019 for all other taxes levied by Poland for taxable periods beginning on or after that date.
The MLI allows jurisdictions to integrate elements of the OECD/G20 BEPS project into their existing bilateral tax treaties. In July, HMRC published the final list of UK reservations and notifications for the UK’s ‘covered tax agreements’ under the MLI.
The authentic legal texts of the 2006 double tax convention and the MLI take precedence and remain the legal texts applicable.
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