PROTOCOL TO THE AGREEMENT BETWEEN THE REPUBLIC OF POLAND AND THE SLOVAK REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
On the signature of the Agreement between the Republic of Poland and the Slovak Republic for the avoidance of double taxation with respect to taxes on income and on capital the signatories below duly authorized thereto, have agreed as follows:
- (1) Since the entry into effect of this Agreement the Republic of Poland and the Slovak Republic suspend in their mutual relations the application of the Multilateral Convention for the avoidance of double taxation with respect to income and capital of individuals signed in Miskolc on 27 May 1977 and the Multilateral Convention for the avoidance of double taxation with respect to income and capital of legal entities signed in Ulan-Bator on 19 May 1978.
- (2) The computation of the period referred to in Article 5, paragraph (3) of the Agreement shall begin on 1 January 1995.
- (3) The building site or activities referred to in Article 5, paragraph (3) of the Agreement related to contracts concluded before 1 June 1994 shall not be regarded as permanent establishment if they do not exceed 18 months after 1 July 1994.
This Protocol shall form an integral part of the above mentioned Agreement.
IN WITNESS WHEREOF, the undersigned, being duly authorized thereto have signed this Protocol.
DONE in duplicate at Warsaw this 18th day of August 1994 in the Polish, Slovak and English languages, all texts being equally authentic. In case of any divergency of interpretation, the English text shall prevail.