Treaty detail
China - 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
1994-03-28
Effective
1994-09-28
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold of 25 percent under the treaty.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government and central-bank interest.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling under the treaty.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the 1994 treaty wording includes specified habitual-conclusion rules.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1994 wording.
Article 4 reflects the 1994 wording. Residence analysis interacts with China's developing Place-of-Effective-Management rules.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both construction and service-PE rules.
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.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 10 percent and 5 percent treaty ceilings.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 produces a 10 percent ceiling with carve-outs for qualifying government and central-bank interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling.
Article 12 limits royalties at 10 percent across the core categories.
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–KR treaty
- TreatyUS–CN treaty
- TreatyGB–CN treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyAU–KR treaty
- TreatyCN–DE treaty
- TreatyDE–KR treaty
Primary sources
- State Taxation Administration of ChinaVerified 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.