The income tax treaty between Georgia and South Korea was signed on 31 March 2016. The treaty is the first of its kind between the two countries.
The treaty covers Georgian profit tax and income tax, and covers Korean income tax, corporation tax, special tax for rural development and local income tax.
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
The beneficial provisions of Articles 10 (Dividends), 11 (Interest), 12 (Royalties), 13 (Capital Gains) and 21 (Other Income) will not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares, debt-claims or other rights in respect of which the dividends, interest, royalties, gains or other income are paid was to take advantage of those Articles by means of that creation or assignment. The limitation is included in each of those Articles.
Both countries apply the credit method for the elimination of double taxation.
The treaty will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.
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