Date of Implementation

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New Article 23 amends the method of elimination of double taxation. It now provides that if a Polish resident’s income is liable to tax in Malta, the amount paid will be subject to a tax deduction in Poland.
Article 25 – Mutual Agreement Procedure has been changed. The amendment states that the competent authority will try to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to namibia mobile database the avoidance of taxation which is not in accordance with the agreement. Any agreement reached shall be implemented notwithstanding obligations under the domestic law of the Contracting States.
Exchange of Information – Article 26, authorises the use of such information, received by a Contracting State for other purposes, provided that the competent authority of the supplying State authorises such use.
A new Article 26A has also been inserted which provides for the prevention of tax treaty abuse practices.

The changes will come into the force the first day of January of the year following the date on which the Protocol comes into force.