Poland and Singapore signed an Income Tax Treaty on 4 November 2012. The treaty which is not yet in force was concluded in both the Polish and English languages, each text having equal authenticity. The treaty generally follows the OECD Model, with some deviations.
The definition of a permanent establishment under the treaty includes the provision of services in the other contracting state through employees or other personnel engaged for the purpose but only if the services continue on the same project or connected projects for at least 365 days in any 15 month period.
The maximum withholding tax rate on dividends is 10% but is reduced to 5% if the beneficial owner is a company which controls directly at least 10% of the capital of the company paying the dividends and has held at least 10% of the capital for an uninterrupted 24-month period.
Dividends paid to certain public bodies are exempt from withholding tax. Also the withholding tax on interest is reduced to 5%, subject to certain exceptions. For royalties the withholding tax is generally 5% but is 2% for the use of, or the right to use any industrial, commercial, or scientific equipment.
