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Worldwide Tax Summaries--POLAND(1999-2000)(part1)(二)
作者: 文章来源:中立诚 点击数: 更新时间:2006-7-11 20:10:00
;          10
United States        15(38)          0                10
Uruguay            15             15               15
Uzbekistan          15(7)           10(14)           10
Vietnam            15(32)          10               15(39)
Yugoslavia (former)   15(1)           10               10
Zimbabwe           15(32)         10                10

Notes:
The numbers in parentheses refer to the notes below.
1. 5% if the recipient company holds directly at least 25% of the share capital of the paying company.
2. 5% if the recipient company holds directly more than 30% of the share capital of the paying company.
3. 0% for interest on current accounts or registered loans between banks and interest received by the state.
4. 0% if interest is paid in respect of a loan made or guaranteed by the government of the other state, its local authorities, the central bank of the contracting state, or any financial institution controlled by the government of the contracting state.
5. 0% on royalties from copyrights of literary, dramatic, musical or artistic works (excluding royalties in respect of motion picture films and works on film or videotape for use in connection with television).
6. 10% of 70% of gross income arising from payments for the use of or the right to use any industrial, commercial or scientific equipment.
7. 5% if the recipient company holds directly at least 20% of the capital of the company paying the dividends.
8. 10% of payments received as a consideration for the use of or the right to use any patent, trademark, design or model, plan, secret formula or process, or any industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
9. 5% if the recipient company holds directly at least 10% of the payer's capital.
10. 0% on royalties from copyrights of literary, artistic or scientific works.
11. 25% if the difference in tax rates on undistributed and distributed profits is 20% or more.
12. 0% on interest on certain trade loans or credits.
13. 10% if the recipient company holds directly at least 20% of the capital of the paying company.
14. As per note (4), but without the phrase “or guaranteed.”
15. 0% if the recipient company holds directly at least 25% of the voting power of the payer.
16. 0% on interest paid in connection with the sale on credit of any industrial, commercial or scientific equipment or of any merchandise by one enterprise to another or on any loan granted by a bank.
17. 0% on fees for technical services.
18. 5% if the recipient company holds directly at least 15% of the payer's capital.
19. A lower rate of 5% is applicable for the use of or the right to use industrial, commercial or scientific equipment.
20. 0% on cultural royalties (payments for the use of or the right to use any copyright of literary, artistic pr scientific work, including cinematographic films and films or tapes for radio or television broadcasting) if the beneficial owner is resident in the other state.
21. 0% on interest paid in connection with the sale on credit of any industrial, commercial or scientific equipment or of any merchandise by one enterprise to another enterprise.
22. 0% on interest paid in respect of bank credits or loans or on interest derived by a contracting state for its own account.
23. Interest on an approved loan or long-term loan and royalties paid to a resident of Poland are exempt from Malaysian tax, subject to approval by the competent authority of Malaysia.
24. Where the dividends are paid by a company resident in Malta to a resident of Poland that is the beneficial owner thereof, Malta tax on the gross amount of the dividends should not exceed that chargeable on the profits out of which the dividends are paid.
25. 5% if the recipient company holds d

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