- 1
- The provisions of subparagraph b) of paragraph 2 of Article 10 shall not apply to dividends paid by or to a person who is a Fiscal Investment Institution (Fiscale Beleggingsinstelling) for the purposes of the company tax of the Netherlands or by or to a person who is an open ended investment fund, exempt for the purpose of the corporate income tax in Poland, respectively.
- 2
- It is understood that income received in connection with the (partial) liquidation of a company or a purchase of own shares by a company is treated as income from shares.
- 3
- It is understood that income received in connection with distributions on certificates or participating units of an investment fund is treated as income from shares.