The date when the changes to the double taxation convention come into effect

In accordance with the provisions of the protocol, the changes that will be introduced into the double taxation convention will come into effect with the day on which later of the notes stipulated in the protocol is received. The provisions of the protocol will be applied in the countries being parts of the double taxation convention:

  • with reference to the withholding tax, to the amount obtained on 1 January or after that day in the calendar year successive after the year in which the present protocol comes into effect;
  • with reference to other income taxes, taxes due for the tax year beginning on 1 January or after that day in the calendar year successive after the year in which the present protocol comes into effect.

By the way, it should be also pointed out that the date of ratification of the protocol by both parties is not known, and thus the date of coming into effect the changes to the double taxation convention between The Republic of Poland and The Republic of Cyprus is postponed in time. However, it cannot be excluded that the changes will already come into effect on 1 January 2013.