(1) The profits of an enterprise of a Contracting State shall be taxable only by that State
unless the enterprise carries on business in the other Contracting State through a permanent
establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the
enterprise may be taxed by the other Contracting State but only so much of them as is
attributable to that permanent establishment.
(2) Where an enterprise of a Contracting State carries on business in the other Contracting
State through a permanent establishment situated therein, there shall in each Contracting State be
attributed to that permanent establishment the profits which it might be expected to make if it
were a distinct and separate enterprise engaged in the same or similar activities under the same or
similar conditions and dealing wholly independently with the enterprise of which it is a
permanent establishment.
(3) In the determination of the profits of a permanent establishment there shall be allowed as
deductions expenses which are incurred for the purposes of the permanent establishment,
including executive and general administrative expenses so incurred, whether in the State in
which the permanent establishment is situated or elsewhere.
(4) No profits shall be attributed to a permanent establishment by reason of the mere
purchase by that permanent establishment, or by the enterprise of which it is a permanent
establishment, of goods or merchandise for the enterprise.
(5) Where profits include items of income which are dealt with separately in other articles of
this Convention, the provisions of those articles shall, except as otherwise provided therein,
supercede the provisions of this Article.
Citation to select or copy
Poland / United States; IRS/Treasury official source publication; edition us-pl-1974-convention; article 8; English; unreviewed source text, current applicability unverified; /editions/us-pl-1974-convention/en/articles/article-8/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
IRS lists the 1974 income tax treaty and separate technical explanation; its review/update is 7 May 2026, not a treaty date. Treasury separately lists a convention signed on 13 February 2013 and explains that it posts documents upon signature before ratification and entry into force. These directory captures establish a separately signed 2013 convention, not whether it entered into force or replaced the 1974 convention. The 2013 entry/replacement status remains unverified here. Do not label 2013 operative, 1974 superseded, or 2013 definitively never in force from these pointers alone. Retain this 1974 reader and keep the 2013 instrument separate; no generic default warning is needed beyond the edition-relationship label.
existing retained signature metadata; not newly verified by directory captures
1974-10-08
Treasury-reported 2013-convention signature, not entry/effects
2013-02-13
IRS page review/update, not treaty signature/entry
2026-05-07
2013 entry/replacement not established by reused evidence
No universal date asserted
Retained status evidence and exact quotes
Internal Revenue Service (IRS) · IRS lists a 1974 treaty document; directory evidence, not by itself a conclusive bilateral force certificate
Publisher-reported status only. Currentness and human legal approval remain unverified.
Edition
us-pl-1974-convention
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1974-10-08
Currentness verified
False
Languages recorded in source metadata: English, Polski. This is not a promise of available text or a translation.
Edition notes and known limitations
Private review only. Original source edition, not current-law certification.
Full text: native/us-pl-1974-convention/layout.txt; physical page ledger: native/us-pl-1974-convention/quality.json
Known protocols and technical/status reference links retained separately in source-index.json. No silent merging.
v2 QA repair: closing/attached notes are separate searchable source supplements; verified physical folios are page markers, not legal paragraph blocks. Source bytes unchanged.
Source authority, text completeness and currentness still require human review.
IRS lists the 1974 income tax treaty and separate technical explanation; its review/update is 7 May 2026, not a treaty date. Treasury separately lists a convention signed on 13 February 2013 and explains that it posts documents upon signature before ratification and entry into force. These directory captures establish a separately signed 2013 convention, not whether it entered into force or replaced the 1974 convention. The 2013 entry/replacement status remains unverified here. Do not label 2013 operative, 1974 superseded, or 2013 definitively never in force from these pointers alone. Retain this 1974 reader and keep the 2013 instrument separate; no generic default warning is needed beyond the edition-relationship label.