Korean Supreme Court Decision on Treatment of Collective Investment Vehicles under Tax Treaty with Luxembourg
An important decision of South Korea's Supreme Court was issued in 2020 regarding whether Luxembourg investment companies with variable capital (SICAVs) established as exempt Undertakings for Collective Investment in Transferable Securities were eligible for reduced withholding tax rates on dividends and interest under the 1984 Korea-Luxembourg tax treaty.
The activities of the taxpayers inclu…
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