Treaty detail
South Korea - Thailand tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1989-11-16
Effective
1991-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The Korea-Thailand treaty, as amended by its later protocol, generally applies a uniform cap on cross-border dividends. The precise outcome still depends on beneficial ownership and Article 10.
Interest
Rate: 15%
Interest paid to banks or financial institutions is generally subject to a reduced rate. Government-related interest may be exempt under the treaty.
Royalties
Rate: 15%
Royalty treatment under this treaty is article-specific. The treaty caps the source-country rate at a higher level than in many modern treaties, reflecting its older vintage.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where a person habitually concludes contracts or maintains a stock of goods on behalf of the enterprise, consistent with the older UN-influenced template.
Other treaty flags
Pension taxation is generally allocated to the residence state, with separate rules for government-service pensions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to any benefit under the treaty.
Residence under the Korea-Thailand treaty matters especially for individuals working under regional secondment arrangements where dual residence is common.
Article 5
Permanent Establishment
Sets the business-presence threshold with a services-PE element.
The Korea-Thailand treaty follows the older UN-influenced template and includes a services threshold in addition to the construction threshold.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Article 7 is the operating rule for cross-border services, distribution, and operating subsidiaries between Korea and Thailand.
Article 10
Dividends
Provides the treaty cap on cross-border dividend withholding.
Article 10, as updated by the 2006 protocol, distinguishes between qualifying corporate shareholders and other beneficial owners. The precise thresholds should be confirmed against the official text.
Article 11
Interest
Caps source-country withholding on cross-border interest with broad government-interest carve-outs.
Article 11 includes a tiered rate structure with a higher general cap and a reduced rate for financial-institution interest. Government-related interest may be fully exempt.
Article 12
Royalties
Caps source-country withholding on royalties at a rate higher than in modern OECD-style treaties.
Royalty rates under the Korea-Thailand treaty reflect its 1989 vintage. The precise rate should be confirmed against Article 12 for the specific royalty category.
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
- TreatyAU–KR treaty
- TreatyDE–KR treaty
- TreatyJP–KR treaty
- TreatyIN–KR treaty
- TreatyCN–KR treaty
- TreatyKR–SG treaty
- TreatyJP–TH treaty
Primary sources
- Korea National Tax Service - international tax treatiesVerified 2026-05-20
- Thai Revenue Department - international taxationVerified 2026-05-20
- OECD MLI signatories and partiesVerified 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.