irectly at least 25% of the share capital of the paying company.
26. 7% if the recipient company holds directly at least 25% of the share capital of the paying company.
27. 0% if the recipient company holds directly at least 25% of the share capital of the paying company.
28. According to protocol, the contracting state will refund the tax if the fiscal authorities of the other contracting state confirm that no tax credit can be obtained in that other contracting state.
29. The lower rate of 15% is applicable only if the beneficial owner controls at least one-third of the company's stock.
30. 0% on interest paid to a Polish company on loans approved by the Pakistan Ministry of Finance and interest derived by the Central Bank of Pakistan and Bank Handlowy w Warszawie S.A.
31. A lower rate of 15% applies to payments received as consideration for technical know-how or information concerning industrial, commercial or scientific experience.
32. 10% if the recipient company holds directly at least 25% of the capital of the paying company.
33. 5% if the recipient company holds directly at least 25% of the voting power of the paying company.
34. 0% according to protocol , as long as Switzerland does not levy withholding tax on royalties paid to nonresidents.
35. 10% if the interest is received by a financial institution
(including an insurance company).
36. The lower rate of 5% is applicable for copyright of literary, artistic or scientific work, excluding cinematographic films or tapes for television or broadcasting.
37. 0% on dividends of which the beneficial owner is the government or any government agency or a company the capital of which is owned directly or indirectly at least 25% by the government or governmental institutions of either party.
38. 5% if the recipient company is the beneficial owner, holding directly or indirectly at least 10% of the voting power of the paying company.
39. 10% if payments are received as consideration for the use of any patent, trademark, design or model, plan, or secret formula or for information concerning industrial or scientific experience.
Poland is also a member of the Comecon multilateral double taxation treaty until OECD-type treaties between the former Comecon members come into force.
TAX ADMINISTRATION
Returns/Generally, companies are required to file monthly returns for tax advances paid during the year. These should be filed by the 20th day of the month following the reported month. Under certain circumstances, taxpayers may file only one half-year return.
In addition a company liable to tax is required to file a preliminary annual return with the tax office according to a specified format. The return should state the amount of income earned in the fiscal year and should be filed by the end of the third month following the end of the taxpayer's fiscal year. In this period the company must pay the difference between the tax due on income stated in the return and the sum of monthly tax advances paid for the period from the beginning of the year. Taxpayers must file returns of the final amount of their
income (if it differs from the amount disclosed in the preliminary return) within ten days of the approval of their yearly financial statements by the general annual shareholders' meeting but not later than nine months after the end of the taxpayer's fiscal year.
Payment of tax/Generally, the taxpayer must pay monthly advances in amounts equal to the difference between the tax due on the income earned since the beginning of the year and the sum of advances paid for preceding months. The monthly advances for the 1st to the 11th months of the taxpayer's fiscal year are payable no later than the 20th of the following month. By the 20th day of the 12th month the taxpayer must remit an amount equal to twice the tax due for the 11th month. This
payment covers the tax advances due for both the 11th and 12th months.
In other words, there is no tax advance due by the 20th of the first month of the next year.
Having met certain requirements, the taxpayer may also pay tax advances as follows.
1. For each of the first five months of the fiscal year, one-sixth of the tax due for the first six months of the preceding fiscal year.
2. For the sixth month of the fiscal year, the difference between the tax due for the six months and aggregated amounts of tax advances calculated as in (1) above.
3. For each of the subsequent six months of the fiscal year, one-sixth of the tax due as disclosed in the half-year declaration.
The law requires all tax and related payments as well as payments made between business entities to
[1] [2] 下一页
上一页 [1] [2] [3] [4] [5] [6] 下一页
