Polish administrative court rules on “look-through” approach related to withholding tax on interest paid through a bank account of a Korean real estate trust

Executive summary
On 4 February 2020, the Voivodeship Administrative Court in Gliwice (VACG) issued its decision in a case that relates to a Korean investment institution (Investor) which receives interest payments from a Polish entity. Under the arrangement, interest payments are made through a trust bank account in Poland owned by a Korean real estate fund (Fund) and transferred to the Investor. …
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