Treaty detail
India - 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
2015-05-18
Effective
2016-09-12
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 15%
The 2015 treaty applies a 15 percent ceiling on dividends. India's 2020 shift on dividend taxation affects how the article applies in practice.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government and central-bank interest.
Royalties
Rate: 10%
Royalties and fees for technical services generally face a 10 percent ceiling under the 2015 treaty.
Permanent establishment
Construction threshold: more than 9 months
Dependent-agent analysis follows BEPS-era updated wording in the 2015 treaty.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned rules.
Article 4 reflects the 2015 modernized wording.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both construction and service-PE rules under the 2015 wording.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows OECD-aligned profit-attribution principles.
Article 10
Dividends
Caps source-country dividend withholding at a 15 percent ceiling.
Article 10 applies a 15 percent ceiling on dividends.
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 and Fees for Technical Services
Caps royalties and FTS at a 10 percent ceiling.
Article 12 combines royalties and FTS at a 10 percent ceiling under the 2015 treaty.
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–IN treaty
- TreatyGB–IN treaty
- TreatyCA–IN treaty
- TreatyAU–IN treaty
- TreatyAU–KR treaty
- TreatyDE–IN treaty
- TreatyDE–KR treaty
Primary sources
- Income Tax Department of India - DTAA listVerified 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.