Executive summaryOn 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. The VACG confirmed that the role of the Fund in the structure is to transfer profits through interest due on loans receivables paid by the Polish entity to the Fund’s beneficiary (Investor). Accordingly, the preferential tax rate applicable to...