Poland has 82 tax agreements in force, as reported in its response to the Peer Review questionnaire. Twenty-four of those agreements, the agreements with Australia, Austria, Belgium, Canada, Denmark, Finland, France, Iceland, India, Ireland, Israel, Japan, Lithuania, Luxembourg, Malta, New Zealand, Norway, Serbia, Singapore, the Slovak Republic, Slovenia, Ukraine, the United Arab Emirates, and the United Kingdom, comply with the minimum standard.

Poland signed the MLI in 2017 and deposited its instrument of ratification of the MLI on 23 January 2018. The MLI entered into force for Poland on 1 July 2018. Poland has not listed its agreements with Georgia, Germany and Montenegro but indicated in its response to the Peer Review questionnaire that bilateral negotiations would be pursued with respect to those agreement.

Poland is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

No jurisdiction has raised any concerns about their agreements with Poland.


← 1. For its agreements listed under the MLI, Poland is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Poland expressed a statement that while it accepts the application of the PPT under the MLI, it intends where possible to adopt an LOB provision through bilateral negotiation.

← 2. The tax agreement concluded between Poland and the Netherlands in 2002 has been notified by Poland as “covered” under the MLI. The Netherlands didn’t notify the tax treaty with Poland as “covered”. In order to introduce to the above DTA the minimum standard provided for in the BEPS Action 6, bilateral negotiations were held. On 29 October 2020, the Protocol amending this tax agreement was signed. The Protocol provides for, amongst others, the inclusion of the preamble statement and the PPT clause in the DTA. As soon as the Protocol comes into force and is effective, this DTA will include the minimum standard resulting from the BEPS Action 6.

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