Luxembourg-Poland protocol eliminates PE exemption, affecting US investments in Poland

July 2012


The recent Luxembourg - Poland treaty protocol contains numerous revisions. The most significant impact from a US federal income tax perspective is with respect to structures involving Luxembourg branches of Polish companies. This structure has applied to inbound and outbound structures, and has been commonly used to finance a group's US and non-US subsidiaries. This recent development has potential relevance for companies that claim benefits under the United States-Poland income tax treaty.

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Bernard Moens
Principal and US Inbound International Tax Services Leader
Tel: +1 (202) 414 4302

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