Elimination of Double Taxation of Fees for Technical Services in Bilateral Tax Treaties Concluded by Poland
Elimination of Double Taxation of Fees for Technical Services in Bilateral Tax Treaties Concluded by Poland

Summary/Abstract: This paper deals with the Polish treaty practice in the field of elimination of doubletaxation of fees for technical services in the context of Article 12A of the UN Model asamended in 2017. An analysis of the solutions present in bilateral tax treaties concluded byPoland both before and after 2017 with the countries currently referred to as the countriesof the so-called Global South allows us to put forward a thesis that a separate model so-lution to the issue of fees for technical services is needed. The considerations containedin the article show that Article 12A of the UN Model, which regulates this issue, if it be-comes a permanent element of Polish treaty practice, may contribute to solving some ofthe problems that arise in the context of the classification of this category of income. Itmay also contribute to the unification of Polish treaty practice in this area.

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