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 Tax Treaty
Tax on non-residents may be reduced or exempted by applicable tax treaties, conventions or agreements between Korea and the domiciliary countries.
Rates of taxation on interest, dividends, and capital gains will vary according to the relevant tax treaties.
If the tax treaties are in conflict with the domestic tax laws of the concerned country (as given below), the tax treaties take precedence over the latter.
<Income Tax Withholding Rates for Countries With Tax Treaties>
(Unit: %)
Country Dividends
Interest Capital Gainsd
Australia 5 or 15c 15 0
Austria 10 or 15c 10 0
Bangladesh 10 or 15c 10 0
Belasus 5 or 15c 10 0
Belgium 15 10 0
Brazil 15 10 or 15b 0
Bulgaria 5 or 10c 10 0
Canada 15a 15a 0
Chile 5 or 10c 10 or 15b 0
China 5 or 10c 10 0
Czech Republic 5 or 10c 10 0
Denmark 15 15 0
Egypt 10 or 15c 15 0
Fiji 10 or 15c 10 0
Finland 10 or 15c 10 0
France 10 or 15c 10 0
Germany 5 or 15c 10 0
Greece 5 or 15c 8 0
Hungary 5 or 10c 0 0
India 15 or 20c 10 or 15b 0
Indonesia 10 or 15c 10 0
Ireland 10 or 15c 0 0
Israel 5 or 15c 7.5 or 10 0
Italy 10 or 15c 10 0
Japan 10 or 15c 10 0
Kazakhstan 5 or 15c 10 0
Kuwait 10 10 0
Luxemburg 10 or 15c 10 0
Malaysia 10 or 15c 15 0
Malta 5 or 15c 10 0
Mexico 0 or 15c 10 or 15b 0
Myanmar 10 10 0
Mongolia 5 5 0
Morocco 5 or 10c 10 0
Nepal 5 or 10c or 15c 10 0
Netherlands 10c or 15c 15 0
New Zealand 15 10 0
Norway 15 15 0
Pakistan 10-12.5c 12.5 0
Papua New Guinea 15 10 0
Philippines 10 or 15 10 or 15 0
Poland 5 or 10c 10 0
Portugal 10 or 15c 15 0
Rumania 7 or 10c 10 0
Russia 5 or 10c 0 0
South Africa, Rep. 5 or 15 10 0
Singapore 10 or 15c 10 0
Slovakia 5 or 10c 10 0
Spain 10 or 15c 10 0
Sri Lanka 10 or 15c 10 0
Sweden 10 or 15c 15 0
Switzerland 10 or 15c 10 0
Thailand 15 or 20c 10 0
Tunisia 15 12 0
Turkey 15 or 20c 10 or 15b 0
Ukraine 5 or 15c 5 0
United Kingdom 5 or 15c 10 0
United States 10 or 15 12 0
Uzbekistan 5 or 15 5 0
Vietnam 10 10 0

* Notes : Includes the exemption based on the reciprocity without the tax treaties
a) Tax treaty does not exempt resident tax and thus the above tax rate has been increased.
b) Rates vary depending on the term of the loan or debenture.
c) Rates vary depending on whether the dividend paying company is owned over a particular percentage by it.
d) Korea does not levy capital gains tax against tax treaty nations except in some special cases.
* For more details, please refer to the original tax traeties.
* Source: National Tax Service (as of Jan 2004)
 
[Capital Gains Tax for Countries With Tax Treaties]
 
Types
Nations
¡Ý Cases where capital gains tax can be levied only in the domiciliary country
Levied only in the domiciliary country on the tax treaty Belarus, Belgium, Bulgaria, Czech Republic, Denmark, Egypt, Fiji, Greece, Hungary, Indonesia, Kuwait, Malaysia, Papua New Guinea, Poland, Portugal, Rumania, Russia, Slovakia, South Africa, Sri Lanka, Switzerland, Tunisia, Uzbekistan, United States
Levied only in the domiciliary country on tax treaty but Korea can withhold capital gains tax if the investment includes a high proportion of real estate
Bangladesh, Canada, China, Finland, France, India, Ireland, Israel, Japan, Malta, Mexico, Myanmar, Mongolia, Morocco, Nepal, New Zealand, Norway, Pakistan, Philippines, Spain, Sweden, United Kingdom, Vietnam
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax on a holding which has been more than 25 percent of an issued stock for a specified period of time
Austria, Canada, France, Israel, Italy, Japan, Mexico, Pakistan, Spain
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax on a holding which has been more than 20 percent of an issued stock for a specified period of time Chile
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax on a holding which has been more than 35 percent of an issued stock Myanmar
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax on stock possessed for less than one year Turkey
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax if the transfer has ever resided for five years preceding the stock transfer Norway
Levied only in the domiciliary country on tax treaty, but Korea can withhold capital gains tax in case transferor as an individual has been a resident at any time in the five years preceding the stock transfer Finland, France, Netherlands, United Kingdom
¡Ý Cases where capital gains tax can be levied both in Korea and treaty nations
Korea can withhold capital gains tax because the tax treaty does not cover capital gains tax
Luxembourg, Thailand
Korea can withhold capital gains tax under the terms of the tax treaty
Brazil, Germany, Ukraine (except listed stock), Kazakhstan (except listed stock), Singapore, Australia


* Note: Although in some cases Korea can withhold capital gains tax from some of the treaty nations mentioned above, capital gains tax is not applied if the transferring investors holds less than 25 percent of the stock of a listed (or registered) company.

* Source: National Tax Service (as of January 2004)