Treaty detail
Australia - South Korea tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1982-07-12
Effective
1984-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 15%
The treaty applies a 15 percent ceiling on dividends without a substantial-direct-ownership reduction in the older 1982 wording.
Interest
Rate: 15%
The 15 percent ceiling can be reduced for qualifying government and central-bank interest under the article.
Royalties
Rate: 15%
Royalties generally face a 15 percent ceiling under the older 1982 treaty.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the older 1982 wording includes specified habitual-conclusion and stock-of-goods rules.
Other treaty flags
Pension treatment is article-specific under the older 1982 treaty wording.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1982 wording.
Article 4 reflects the older 1982 wording. Residence analysis under the treaty interacts with each country's domestic residence rules.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both construction and service-PE rules under the older 1982 wording.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. The service-PE rule in Article 5 affects how it applies in practice.
Article 10
Dividends
Caps source-country dividend withholding at a 15 percent ceiling.
Article 10 applies a uniform 15 percent ceiling without a substantial-direct-ownership reduction.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 15 percent ceiling.
Article 11 reflects the older 1982 ceiling of 15 percent on interest, with carve-outs for government and central-bank interest.
Article 12
Royalties
Caps royalties at a 15 percent ceiling under the older treaty.
Article 12 limits royalties at 15 percent under the older treaty wording. Article-by-article review remains important.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–AU treaty
- TreatyUS–KR treaty
- TreatyGB–AU treaty
- TreatyAU–CA treaty
- TreatyAU–JP treaty
- TreatyAU–SG treaty
- TreatyAU–IN treaty
- TreatyAU–CN treaty
Primary sources
- ATO: tax treatiesVerified 2026-05-20
- Korean NTS treaty informationVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.