🇵🇱 Tax Treaty
Cyprus–Poland Double Tax Treaty
The Cyprus-Poland DTA provides favourable 5% WHT on royalties, interest, and qualifying dividends — significantly below Polish domestic withholding rates and useful for Cyprus-based businesses with Polish operations or customers.
Withholding Tax Rates at a Glance
(reduced rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 10% | Standard WHT rate |
| Dividends (reduced) | 5% | companies holding ≥25% of payer capital |
| Interest | 5% | On interest payments between the countries |
| Royalties | 5% | On royalties, licences, and IP income |
| Capital Gains (Cyprus side) | 0% | 0% in Cyprus on disposal of shares |
Treaty signed: 1992. In force: 1993. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ 5% WHT on royalties (vs Polish domestic 20%)
- ✓ 5% WHT on dividends for ≥25% holdings
- ✓ 5% WHT on interest
- ✓ Capital gains on Polish shares exempted in Cyprus
Common Cyprus–Poland Structures
- → Cyprus IP company licensing software to Polish clients
- → Cyprus holding company above Polish operating company
Planning Notes
Poland is a significant market for many Cyprus-based businesses. The 5% royalty WHT (vs Polish domestic 20%) provides meaningful savings for IP licensing structures. Polish WHT rules have tightened since 2022.
Dual Residency Tiebreaker
Place of effective management
Planning a Cyprus–Poland structure?
Treaty rates are only part of the picture. We help you design and implement Cyprus company structures that take full advantage of the Cyprus–Poland double tax treaty — with genuine substance and robust documentation.