Treaty detail
United Kingdom - 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
1996-10-25
Effective
1996-12-30
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The 1996 treaty as amended by the 2014 protocol applies a 5 percent rate for qualifying corporate holdings and 15 percent more broadly. Article-level qualifying conditions and beneficial-ownership tests apply.
Interest
Rate: 10%
Interest is generally subject to a 10 percent ceiling, with article-based exemptions for qualifying government, bank, and pension cases. The protocol updates affect specific qualifying conditions.
Royalties
Rate: 10%
Royalties are generally subject to a 10 percent ceiling. The article-level definition includes copyright, patent, and know-how, with characterization questions resolved against the article text.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where an agent habitually exercises contract-concluding authority. The 2014 protocol affected specific PE-related provisions.
Other treaty flags
The UK-Korea treaty divides pension rights between source and residence depending on the type of payment. Government-service pensions generally follow source-country rules, with private pensions and lump sums requiring article-level review.
Seeded article summaries
Article 4
Residence
Defines treaty residence and underpins every other treaty claim.
Residence under the UK-Korea treaty controls access to all reduced rates and PE-based protections. Dual-residence questions are resolved using tiebreaker rules updated by the 2014 protocol.
Article 5
Permanent Establishment
Defines the source-country business-presence threshold.
Article 5 follows the OECD pattern with a six-month construction threshold for some activities, reflecting practical recognition of shorter project cycles. Agent and fixed-place tests apply alongside.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief is the practical operating rule for cross-border services and trading between the UK and Korea. Attribution rules apply once a PE exists in the source country.
Article 10
Dividends
Provides reduced treaty rates for qualifying cross-border dividends.
The dividend article applies a 5 percent rate for qualifying corporate holdings and 15 percent more broadly. The 2014 protocol updated specific qualifying conditions.
Article 11
Interest
Caps source-country withholding on interest at the treaty rate.
Interest payments between the UK and Korea are subject to a 10 percent ceiling under the treaty. Qualifying government, bank, and pension cases can produce lower or zero rates.
Article 12
Royalties
Caps source-country withholding on royalties at the treaty rate.
Royalties are subject to a 10 percent ceiling under the UK-Korea treaty. The article-level definition controls characterization for software, IP, and know-how payments.
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–GB treaty
- TreatyUS–KR treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
Primary sources
- HMRC Korea tax treaties pageVerified 2026-05-20
- Korean National Tax Service treaty listVerified 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.