Treaty detail
Japan - 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
1998-10-08
Effective
1999-11-22
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold under the treaty.
Interest
Rate: 10%
The 10 percent ceiling can be reduced to zero 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 12 months
Dependent-agent analysis follows OECD model wording.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1998 wording.
Article 4 reflects modernized OECD-aligned provisions.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The treaty uses the standard 12-month construction-site threshold.
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 treaty ceilings.
Article 10 produces the 15 percent and 5 percent treaty ceilings.
Article 11
Interest
Limits source-country withholding on qualifying interest at 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 source-country royalty withholding to 10 percent.
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–JP treaty
- TreatyUS–KR treaty
- TreatyGB–JP treaty
- TreatyCA–JP treaty
- TreatyAU–JP treaty
- TreatyAU–KR treaty
- TreatyDE–JP treaty
- TreatyDE–KR treaty
Primary sources
- Japan MOF: tax conventionsVerified 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.