Bosnia and Herzegovina: New tax treaty negotiations between Bosnia and Herzegovina and Poland

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Bosnia and Herzegovina: New tax treaty negotiations between Bosnia and Herzegovina and Poland

topic.jpg

Dajana Topic

Negotiations for an income and capital tax treaty between Bosnia and Herzegovina (B&H) and Poland are underway. Once signed and in force, the new treaty will replace the former Yugoslavia – Poland income and capital tax treaty concluded on January 10 1985, in relations between B&H and Poland. Below is a brief review of some terms agreed back in the 1980s, as in practice both countries continued to apply the former conventions.

The tax charged on dividends shall not exceed 5% of the gross amount of the dividends, in case if the recipient is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends and 15% of the gross amount of the dividends in all other cases.

As per interests, the treaty generally stipulates a tax rate at 10%. Where the payer is the state itself, a political subdivision or a local authority, the interest shall be deemed to arise in that state. If the person paying the interest, has in a contracting state a permanent establishment, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the state in which the permanent establishment is situated.

The royalty withholding tax rate has been set at 10%.

Income derived by a resident of a contracting state in respect of professional services or other activities of an independent character shall be taxable only in that state, unless he or she has a fixed base regularly available in the other contracting state for the purpose of performing activities or his or her stay in the other contracting state is for a period amounting to or exceeding in the aggregate 183 days in the fiscal year concerned.

Dajana Topic (dajana.topic@eurofast.eu)
Eurofast Global, Banja Luka Office/B&H

Tel: +387 51 340 680

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The deal for Comtax hands Ryan immediate scale in Brazil, with a near-70-strong team serving clients from São Paulo
The arrivals of Julio Castro and Adam Blakemore mean the firm has added six tax partners to its global practice since the start of 2025
Tax authorities have gained unprecedented transparency through CbCR, but a new study suggests they may not be looking in the right places
The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
More than 200 tier promotions reshaped this year's European rankings as several international firms strengthened their positions in key tax markets
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Asia-Pacific Tax Awards
Monica Erasmus-Koen and her Taxtimbre team will be responsible for building the firm’s TP capability in the competitive Netherlands market
Haynes Boone’s new London partner, Alexandra Ueno-Park, argues that one-size-fits-all policies, billable-hour targets and outdated networking expectations can hold talent back
Howden’s Rian Bahia explains how tax insurance can address known risks, unlock transactions and offer an alternative route through disputes and uncertainty
Gift this article