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Protocol to treaty between Poland and Malta – details

12 May 2011

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Treaty Development

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Poland; Malta

Details have become available of the amending protocol to the Malta and Poland income tax treaty of 7 January 1994, signed on 6 April 2011). The protocol contains a new exchange of information provision (Art. 17) in line with Art. 26 of the OECD Model Tax Convention. Art. 3 provides that a building site or construction or assembly or installation project constitutes a permanent establishment, where such site or project continues for more than 12 months. Art. 8 replaces Paras. 2, 4 and 5 of Art. 10 of the treaty and provides, inter alia, for the maximum rates of withholding...