Details have become available of the amending protocol, signed on 22 March 2012, to the Cyprus - Poland Income and Capital Tax Treaty (1992). The maximum rates of withholding tax are: – 5% on dividends generally, but 0% if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of 24 months (article 4 of the protocol); –   5% on interest (article 5 of the protocol); –   5% on royalties (article 6 of the protocol). Directors' fees and other similar...