The protocol to the Poland-Denmark DTT (which was concluded in 2009) came into force on 25 November 2010. This means that the provisions of the protocol apply from 1 January 2011.

The protocol changes the method of avoidance of double taxation for Polish tax residents. It introduces a so called “exemption with progression method” as a rule. This means that a Polish entrepreneur operating through a branch in Denmark should not include in its taxable base, revenues and costs generated by its Danish branch (this should not also affect CIT rate in Poland, since Poland applies flat CIT rate).

More information can be found in Tax & Legal Alert prepared by experts from PwC - download HERE