Introducing Important Changes Concerning the Avoidance of Double Taxation Between Czech Republic and Poland

On January 1, 2013 a new treaty between the Czech Republic and the Republic of Poland dealing with avoidance of double taxation as well as prevention of tax evasion in the field of income tax has come into effect. The treaty newly introduced the taxation of income of the permanent establishment, changes in rates of dividend taxes, interest rates and royalties, and, last but not least, what has been altered is even the definition of royalties. Furthermore, the treaty also brings a new adaptation of the profits of associated enterprises. Approval of the clause regarding exchange of information as well as cancellation of the tax-sparing clause is a novelty. This article is dealing with the description of the changes and novelties and the indication of the potential importance.