The amending protocol to the 2002 income tax treaty between the Netherlands and Poland will enter into force on 30 April 2022. The protocol, signed 29 October 2020, 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 par…