On the 1st of December 2020, Poland and Malta have signed a protocol amending the 1994 income tax treaty. According to the Polish Ministry of Finance, the protocol provides for the implementation of the minimum BEPS standards and, in particular, includes amendments providing for
This is the second similar protocol to be put forward by Poland with other EU member Countries. The First was signed with The Netherlands. In both Malta’s and Netherlands’ case, the Polish Ministry of Finance said these protocols were necessary because neither contracting state had introduced such changes with Poland when discussing the introduction and implementation of the MLI Convention with each other.
As to when this protocol will enter into force, further details will be published once available.