Korea-Georgia Tax Treaty

The Korea-Georgia Tax Treaty became effective from November 17, 2016 following ratification by the National Assembly on November 3, 2016.   Both governments officially signed the treaty on March 31, 2016.

The treaty includes the following key points:

■ Taxes Covered (Article 2)

Korea taxes covered by the treaty include income tax, corporation tax, special tax for rural development and local income tax in Korea.  In the case of Georgia, the covered taxes include profit tax and income tax.

■ Permanent Establishment (Article 5)

A building site or construction or installation project constitutes a permanent establishment only if it lasts more than nine months.

■ Reduced withholding tax rates (Article 10~12)

(1) Dividends: the withholding tax rate on dividends is limited to 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends or 10% in other cases.

(2) Interest: The withholding tax rate on interest is limited to 10%.

(3) Royalties: The withholding tax rate on royalties is limited to 10%.

Korea-Serbia Tax Treaty

The Korea-Serbia Tax Treaty took effect on November 17, 2016 following ratification by the National Assembly on November 3, 2016.   Both governments officially signed the treaty on January 22, 2016.

The treaty includes the following key points:

■ Taxes Covered (Article 2)

Korea taxes covered by the treaty include income tax, corporation tax, special tax for rural development and local income tax in Korea.  In the case of Serbia, the covered taxes include corporate income tax and personal income tax.

■ Permanent Establishment (Article 5)

A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months.

■ Reduced withholding tax rates (Article 10~12)

(1) Dividends: the withholding tax rate on dividends is limited to 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends or 10% in other cases.

(2) Interest: The withholding tax rate on interest is limited to 10%.

(3) Royalties: The withholding tax rate on royalties is limited to 5% on the payments received as consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting and 10% on the payments received as consideration for the use of, or the right to use, any patent, trade mark, design or model, plan, etc.

Korea-Turkmenistan Tax Treaty

The Korea-Turkmenistan Tax Treaty came into force on November 26, 2016 following ratification by the National Assembly on September 7, 2016.   Both governments officially signed the treaty on April 13, 2016.

The treaty includes the following key points:

■ Taxes Covered (Article 2)

Korea taxes covered by the treaty include income tax, corporation tax, special tax for rural development and local income tax in Korea.  In the case of Turkmenistan, the covered taxes includes tax on profits (income) of juridical persons and tax on income of individuals.

■ Permanent Establishment (Article 5)

A building site or construction or installation project will be considered to constitute a permanent establishment if it lasts more than 12 months.

■ Reduced withholding tax rates (Article 10~12)

(1) Dividends: The withholding tax rate on interest is limited to 10%.

(2) Interest: The withholding tax rate on interest is limited to 10%.

(3) Royalties: The withholding tax rate on royalties is limited to 10%.

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