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

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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 arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
E-invoicing is currently characterised by dynamism, with fragmentation acting as a key catalyst for increasing interoperability, says Aida Cavalera of the International Observatory on eInvoicing
Pillar two and the US tax system ‘could work in harmony’, Scott Levine tells ITR in an exclusive interview to mark his arrival at Baker McKenzie
Peter White, who has a tax debt of A$2 million, has been banned for five years from seeking registration with Australia’s Tax Practitioners Board (TPB)
Wopke Hoekstra’s comments followed US measures aimed against ‘unfair foreign taxes’; in other news, Grant Thornton and Holland & Knight made key tax partner hires
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance
Following his Liberal Party’s election victory, one source expects Mark Carney to follow the international consensus on pillar two, as experts assess the new administration
A German economics professor was reportedly ‘irritated’ by how the Finnish ministry of finance used his data
Gift this article