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Korea (Rep.)-Thailand

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Treaty between Korea (Rep.) and Thailand – details

The new income tax treaty between Korea (Rep.) and Thailand, signed on 16 November 2006, entered into force on 29 June 2007 and applies from 1 January 2008, replacing the previous income tax treaty of 26 August 1974. The tax treaty was concluded in Korean, Thai and English languages, each text having equal authenticity. In case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention (2005).

The maximum rates of withholding tax are:

-   10% on dividends;
-   15% on interest in general, and 10% on interest beneficially owned by a financial institution (including an insurance company) and on interest paid on a credit sale in respect of any equipment, merchandise or service. Interest derived by the government of the contracting states or specified institutions are exempt;
-   5% on royalties for the use of any copyright, artistic or scientific work, including software, motion pictures and works on film, tape or other means of reproduction used in radio or television broadcasting;
-   10% for the use of any patent, trademark, design or model, plan, secret formula or process; and
-   15% for the use of industrial, commercial or scientific equipment and experience.

Deviations from the OECD Model include:

-   the term "resident of a Contracting State" in Art. 4 (Resident) includes a place of head or main office and a place of incorporation. In addition, if a person other than an individual is a resident of both contracting states, the competent authorities of both states will settle the question by mutual agreement;
-   a PE includes a building site, a construction, installation or assembly project or connected supervisory activities if such site, project or activities lasts for a period of more than 6 months;
-   the furnishing of services, including consultancy services, by a resident through employees or other personnel engaged by the resident for such purpose, constitutes a PE only where the activities continue (for the same or a connected project) for a period aggregating more than 6 months within a 12-month period;
-   a PE includes a person, other than an independent agent, who maintains goods and merchandise from which regular deliveries are made on behalf of the principal;
-   when the activities of an agent are devoted wholly on behalf of the enterprise through which it carries on business, and conditions are made or imposed between the enterprise and the agent which differ from those which would have been made between independent enterprises, the agent will not be considered as an independent agent;
-   the income or profits from the operation of ships or aircraft in international traffic includes (i) income or profits from the rental of ships or aircraft fully equipped, manned and supplied, (ii) income or profits from the occasional rental of a ship or aircraft on a bareboat charter, and (iii) the use, maintenance or rental of containers used in the transport of goods or merchandise, where such use is incidental to the operation of ships and aircraft in international traffic;
-   tax may be imposed on the disposal of profits out of a contracting state not exceeding 10% of such profits;
-   Art. 15 (Dependent personal services) states that employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a contracting state shall be exempt in the other contracting state;
-   the tax treaty includes an article on independent personal services; and
-   the tax treaty does not contain a provision concerning assistance in the collection of taxes.

Both states generally provide for the credit method to avoid double taxation. The tax treaty shall apply for a minimum period of 5 years.

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