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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Poland: Source of income

For the purposes of the credit Article (Elimination of double taxation), profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Poland under the provisions of the agreement are deemed to be income or capital gains from sources in Poland (Article 22(3)). Royalties are deemed to arise in the country of which the payer is a resident (Article 12(5)).