Treaty detail
South Korea - Singapore tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1979-11-06
Effective
1981-04-13
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The lower 10 percent corporate rate generally depends on direct-ownership thresholds.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government and central-bank interest.
Royalties
Rate: 15%
Royalties generally face a 15 percent ceiling under the older 1979 treaty as amended.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis follows the treaty wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific. Singapore's CPF interacts in distinctive ways with the treaty's pension provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1979 wording as amended.
Article 4 has been refined by the 2010 protocol.
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 15 percent and 10 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 15 percent ceiling.
Article 12 limits royalties at 15 percent under the older treaty as amended.
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
- TreatyGB–SG treaty
- TreatyAU–SG treaty
- TreatyAU–KR treaty
- TreatyDE–SG treaty
- TreatyDE–KR treaty
- TreatyJP–KR treaty
- TreatyJP–SG treaty
Primary sources
- Korean NTS treaty informationVerified 2026-05-20
- IRAS: list of DTAsVerified 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.