OPODATKOWANIE UDZIAŁU W ZYSKACH SPÓŁKI OSOBOWEJ NA GRUNCIE UMÓW O UNIKANIU PODWÓJNEGO OPODATKOWANIA
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Date
2005
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Wydział Prawa i Administracji UAM
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TAXATION OF THE INCOME RESULTING FROM THE PARTICIPATION IN A PARTNERSHIP IN THE LIGHT OF THE PROVISIONS OF DOUBLE TAXATION AVOIDANCE AGREEMENTS
Abstract
The subject of the paper are the taxation rules of a partner’s income earned in a partnership
established in another state. The paper focuses predominantly on the specific dogmatic problems
having their origin in the differences resulting from domestic tax laws of member states who are
parties of respective bilateral tax treaties concerning the treatment of a partnership as a subject to
income taxation. The recommendations of the OECD that the state which applies the credit
method is obliged to give credit for the source tax levied on partnership may be considered as convincing.
As of 1 January 2005 the Polish internal tax considers a foreign partnership as a subject
to taxation if the tax law of the state where such a partnership is registered treats it as a legal
person.
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Citation
Ruch Prawniczy, Ekonomiczny i Socjologiczny 67, 2005, z. 2, s. 73-82.
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0035-9629