Treaty detail
United Kingdom - Poland tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2006-07-20
Effective
2007-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 0%
The 2006 treaty allows a zero-percent rate for qualifying corporate parent-subsidiary cases meeting the direct-holding threshold, with a general 10 percent rate otherwise. The article text and current EU directive overlay should be confirmed for specific cases.
Interest
Rate: 5%
The treaty applies a 5 percent ceiling on most interest, with exceptions for qualifying government, bank, and pension cases that can result in zero withholding under the article.
Royalties
Rate: 5%
The 2006 treaty applies a 5 percent rate to qualifying royalties. The article definition includes copyright, patent, and know-how, and equipment-leasing treatment deserves separate review.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules apply where an agent habitually exercises contract-concluding authority. Post-MLI modifications affect qualifying provisions in the treaty.
Other treaty flags
Private pensions are generally taxable only in the residence state under the UK-Poland treaty. Government-service pensions follow a separate rule, and lump-sum and termination payments deserve article-level review.
Seeded article summaries
Article 4
Residence
Defines treaty residence and controls access to the treaty's substantive provisions.
Residence under the UK-Poland treaty is the gateway to every other article. Dual-residence questions are resolved using the tiebreaker rules, and the result drives entitlement to reduced rates and PE-based protections.
Article 5
Permanent Establishment
Defines the source-country business-presence threshold.
Article 5 follows the OECD model with a twelve-month construction threshold. The agency and fixed-place-of-business analysis still drives most practical PE questions for cross-border services and trading businesses.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits protection under the UK-Poland treaty is the practical operating rule for cross-border consulting, services, and trading enterprises. Attribution rules apply once a PE exists in the source country.
Article 10
Dividends
Provides reduced and zero-percent rates for qualifying dividends.
The 2006 UK-Poland treaty modernized the dividend article and supports a zero-percent rate for qualifying parent-subsidiary cases. The qualifying conditions and beneficial-ownership tests still control the practical result.
Article 11
Interest
Caps source-country interest withholding at the treaty rate.
Interest payments between the UK and Poland are common in financing arrangements. The 5 percent ceiling is the headline, but specific government, bank, and commercial-credit cases can qualify for lower or zero rates under the article.
Article 12
Royalties
Caps royalty withholding at the treaty rate.
The royalty article applies a 5 percent rate to qualifying payments. IP-heavy structures benefit from the modest rate, but the article definition still controls characterization for mixed contracts.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Poland tax treaties pageVerified 2026-05-20
- Polish Ministry of Finance international treaty listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.