The Brazil-Poland Double Tax Convention in the Context of the Countries’ Contemporary Tax Treaty Policy and Practice

Abstract

This paper deals with the Brazil-Poland double tax convention for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, signed on 20th September, 2022, in the context of contemporary Brazil’s and Poland’s tax treaty policy and practice. The Author analyses its main features in comparison to Brazil’s and Poland’s positions to the MLI and changes introduced to the OECD and UN Models in 2017. Tax treaty provisions relevant to both countries’ tax treaty policies and practices are also examined. The study concentrates around the research question whether the BR-PL DTC fits into the countries’ contemporary tax treaty policy and practice or whether it is a unique bilateral tax treaty with specific features creating a sui generis pattern for tax treaties: for Brazil – with other OECD Member States and for Poland – with other South American states.