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 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

Despite the decline in profitability, the firm’s tax advisory business delivered a 3.4% revenue growth
Firms are making use of inventories and ample profit margins to avoid or absorb the initial impact of higher tariffs, an OECD report said
While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity
Von Wobeser y Sierra’s head of tax shares best practices for resolving tax controversy and touts his firm’s founding partner as an exemplar of legal practice
ITR concludes its analysis of World Tax’s rankings for 2026 by highlighting the firms that stood out most on a global scale
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Awards
Submit your nominations to this year's WIBL EMEA Awards by 16 February 2026
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Further empowerment of HMRC enforcement has been praised, but the pre-Budget OBR leak was described as ‘shambolic’
Gift this article