Stosowanie polsko-chińskiej umowy o unikaniu podwójnego opodatkowania do Specjalnych Regionów Administracyjnych ChRL
The use of Polish-Chinese agreement on the avoidance of double taxation to the Special Administrative Region of the PRC

Summary/Abstract: This article is an attempt to decide whether in the case of Hong Kong and Macao it is possible to apply the Polish-Chinese agreement on avoidance of double taxation. The background to this is a reflection on the principles of avoidance of double taxation solutions, based on the models developed by the OECD. The author analyzes the material and personal scope of the agreement on avoidance of double taxation between the Republic of Poland and the PRC, highlighting in particular the need for a common interpretation of the agreement’s regulations by the Parties. In this respect, he takes into consideration Polish tax jurisdiction. The author approves of the areas questioning the freedom to use special tax administrative regions of China. Simultaneously, the author calls for the signing, in the case of the studied areas, a separate agreement on the avoidance of double taxation.

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