The new convention between Poland and USA for the avoidance of double taxation

The new Convention for the avoidance of double taxation between Poland and the United States was prepared on a model OECD Convention on Income and on Capital.


Compared with the previous one the agreement amendments include: the scope of the taxation of the royalties, dividends, interest, revenue from immovable property, definitions existing in the contract Convention and the exchange of information. The basic method used in the convention will be exemption with the progression method. The method of proportionality will be applied in the case of income from dividends, interest, royalties, gains from transfer of assets and other income not covered by other provisions of the Convention. The agreement has a provision for the exchange of tax information.


The Convention shall apply to private individuals and legal persons resident or established in Poland, the USA, or in both countries.


Polish President Bronisław Komorowski signed in August  2013 the Act on ratification of a new tax treaty, signed in February by Poland and the United States. The agreement will take effect probably in the early 2014.