Poland - Switzerland Tax Treaty

The tax treaty signed 20 April 2010 between Poland and Switzerland will, among other changes, replace the 5% tax rate applicable to qualifying 25% shareholdings with an exemption for qualifying pension funds (or similar) or where the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the payer's capital on the date the dividends are paid and has done so or will have done so for an uninterrupted 24-month period in which that date falls.

The maximum dividend rate under the tax treaty otherwise remains 15%. The 10% tax rate on interest and royalties will be reduced to 5% with an exemption provided for payments between associated companies (provided the beneficial owner of the interest or royalty is not a partnership).