Amendment of the Korea-Luxembourg Tax Treaty

Protocol

Old provision

Amended provision

■Korean Taxes Covered

(Article 1)

· Income tax

·Corporate tax

·Inhabitant tax

·Income tax

·Corporate tax

·Special tax for rural development

·Local income tax

■Dividends

(Article 4)

·15%

[10% if the beneficial owner is a company (other than a partnership) which holds directly at least25%of the capital of the company payingdividends]

·15%

[10% if the beneficial owner is a company (other than a partnership) which holds directly at least10%of the capital of the company paying dividends]

■Interest

(Article 5)

·10%

·10%

[5% if the interest is paid to a bank]

■Royalties

(Article 6)

·15%

[10% if the royalties are paid for the use of, or the right to use industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience]

·10%

[5% if the royalties are paid for the use of, or the right to use industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience]

■(Article 11)

·Article 28 (Exclusion of certain companies) of the Convention:

This Convention shall not apply to holding companies (societies holding) within the meaning of special Luxembourg laws.

·(Deleted)

■(Article 12)

·(Added)

·Nothing in the Convention shall be construed as restricting, in any manner, the application of any provisions of the laws of a Contracting State which are designed to prevent avoidance or evasion of taxes.