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Update - Amending Protocol to Tax Treaty between the Netherlands and Poland

12 November 2020

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Treaty Development

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Netherlands-Poland

The amending protocol to the 2002 income tax treaty between the Netherlands and Poland was signed on 29 October 2020. The protocol is the first to amend the treaty and includes the following changes: The preamble is replaced in line with BEPS standards; Article 1 (Persons Covered) is replaced to include new provisions on transparent entities or arrangements, providing that income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be considered to be income of a resident of a Contracting State but...