Treaty detail
South Korea - Vietnam tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1994-05-20
Effective
1994-09-09
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The Korea-Vietnam treaty generally applies a uniform cap on cross-border dividends without a separate parent-subsidiary rate. The precise outcome still depends on beneficial ownership and any later administrative guidance.
Interest
Rate: 10%
Interest paid to or guaranteed by the government or central bank of either state is typically exempt. Other categories follow the standard 10 percent cap.
Royalties
Rate: 15%
Royalty treatment is article-specific. The treaty caps the source-country rate at a higher level than most modern OECD-style treaties, reflecting its UN-model influence.
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 UN-model influence.
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-Vietnam treaty matters in particular for Korean expatriate executives and Vietnamese subsidiaries of Korean parent companies, both common fact patterns in the Korea-Vietnam corridor.
Article 5
Permanent Establishment
Sets the business-presence threshold with a services-PE element.
The Korea-Vietnam treaty applies a construction threshold and a separate services threshold, which is common in treaties between developed and developing economies.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Article 7 is the practical operating rule for Korean exporters and service providers serving Vietnamese customers without a fixed base.
Article 10
Dividends
Caps source-country withholding on cross-border dividends.
Article 10 produces a uniform treaty cap regardless of shareholding percentage. The dividend article should be read together with the protocol provisions for any reduced parent-subsidiary outcome.
Article 11
Interest
Caps source-country withholding on cross-border interest with government-interest exemptions.
Article 11 caps the general rate at 10 percent. Government-related and qualifying financial-institution interest may benefit from broader treaty exemptions.
Article 12
Royalties
Caps source-country withholding on royalties at a higher rate than in many modern treaties.
Royalty rates under this treaty reflect its 1990s vintage. Practitioners should confirm the rate against Article 12 for the specific royalty category, particularly for software and know-how.
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–VN treaty
Primary sources
- Korea National Tax Service - international tax treatiesVerified 2026-05-20
- Vietnam General Department of Taxation - internationalVerified 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.