Poland's Ministry of Finance has announced the signing of an amending protocol to the 2002 income tax treaty with the Netherlands. The protocol is the first to amend the treaty and, according to the Ministry, includes:
- The introduction of a general principal purpose test;
- The introduction of a real estate clause (for the taxation of gains from shares deriving value from real estate in a Contracting state);
- The introduction of new rules on permanent establishment;
- The introduction of a trans…