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 included the offering of investment schemes for investment in companies listed on the Korean stock market, as well as in bonds issued by Korean companies. For this purpose, certain custodians were appointed for paying dividends and interest received on the Korean stocks and bonds to the Luxembourg...