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

Countries which care about fair taxation of tech multinationals and equitable global distribution of wealth should back the UN’s tax framework, writes economist Abdelmalek Riad
The cuts disproportionately affected staff in certain positions, the report also found; in other news, MHA announced the €24m acquisition of Baker Tilly South East Europe
The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films
Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency
Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said
WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview
The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
Gift this article