ARTICLE 20
Relief from Double Taxation
Double taxation of income shall be avoided in the following manner:
(1) In accordance with the provisions and subject to the limitations of the law of Poland (as it
may be amended from time to time without changing the general principles hereof), Poland shall
allow to a resident of Poland as a credit against the Polish tax the appropriate amount of taxes
paid to the United States.
(2) In accordance with the provisions and subject to the limitations of the law of the United
States (as it may be amended from time to time without changing the general principles hereof),
the United States shall allow to a citizen or resident of the United States as a credit against the
United States tax the appropriate amount of taxes paid to Poland and, in the case of a United
States company owning at least 10 percent of the voting power of a Polish company from which
it receives dividends in any taxable year, shall allow credit for the appropriate amount of taxes
paid to Poland by the Polish company paying such dividends with respect to the profits out of
which such dividends are paid. Such appropriate amount shall be based upon the amount of tax
paid to Poland, but the credit shall not exceed that portion of the United States tax which such
citizen's or resident's net income from sources within Poland or on income from sources outside
of the United States bears to his entire net income for the same taxable year. For purposes of
applying the United States credit in relation to taxes paid to Poland, the taxes referred to in
paragraph (2) (a) of Article 2 shall be considered to be income taxes.