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of <h1>Article 12 of DTAA: Taxation of Interest Capped at 10% for Beneficial Owners, with Key Exemptions and Conditions.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Poland and another Contracting State addresses the taxation of interest. Interest paid to a resident of one Contracting State by another may be taxed in the recipient's state, but also in the state where it arises, with a maximum tax of 10% if the recipient is the beneficial owner. Certain exemptions apply for interest beneficially owned by government entities or central banks. Definitions and specific conditions are outlined, including exclusions for interest linked to permanent establishments or fixed bases. Special relationships affecting interest amounts are also addressed, ensuring excess payments remain taxable under each state's laws.
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