The new income and capital tax treaty and protocol between Poland and Germany signed on 14 May 2003, entered into force on 19 December 2004. The new treaty generally applies from 1 January 2005.

15% on dividends in general, but 5% if the beneficial owner is a company (other than a partnership) which directly holds at least 10% of the capital in the company paying the dividends. Dividends and interest from rights or debt claims participating in profits, including the income of silent partners and that from profit-sharing bonds and loans, may be taxed in accordance…