The amending protocol to the 1985 income and capital tax treaty between Austria and South Korea was signed on 14 June 2021. The protocol is the second to amend the treaty and includes the following changes:
- The preamble is updated in line with BEPS standards;
- Article 5 (Permanent Establishment) is updated in line with BEPS standards with regard to the exclusion of certain fixed places of business from resulting in a permanent establishment if the overall activity of the fixed place of busine…