Under the Polish Corporate Income Tax Law (CIT), interest due to a non-resident is subject to a 20% withholding tax unless a tax treaty concluded by Poland provides for a lower rate. The tax should be withheld when the payment of interest is made. The payer is liable for collecting and remitting the tax to the relevant tax office. Neither the CIT nor any other tax law, however, provide for a definition of what is "the payment of interest". In particular, it was unclear whether or not a situation in which the interest is compounded constitutes the time of the...