Korea, Rep of Tax News
OECD released discussion draft on transactional profit methods
Treaty between India and Korea (Rep.) – Indian decision on taxability of offshore portion of composite contract
APA between China and Korea (Rep.) signed
Tax law changes for 2008
Introduction of simplified tax regime
Corporate tax cut period for large-scale foreign invested companies extended
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Revised Commentary on Article 7 of OECD Model released
Treaty between Korea (Rep.) and Saudi Arabia signed
Tax law changes for 2007
Final Report on Improving the Resolution of Tax Treaty Disputes
Corporate tax breaks
Report on Attribution of Profits to PEs released
Treaty between Canada and Korea (Rep.) enters into force
Treaty between Korea (Rep.) and Nigeria signed
Proposed changes to commercial and tax laws
Treaty between Korea (Rep.) and Malaysia – pre-approval application procedures for benefits finalized
Treaty between Korea (Rep.) and Canada signed
Treaty between Venezuela and Korea (Rep.) signed
List of low tax jurisdiction to be published
Indian decision on applicability of non-discrimination article in India-Korea (Rep.) tax treaty
Philippine ruling that guarantee fees are not interest under Philippines-Korea (Rep.) tax treaty
Second protocol to treaty between China and South Korea signed
Treaty between Brazil and Korea clarified – MFN clauses
Following a reduction in withholding tax rates in the 2001 protocol to the Australia-US tax treaty, Australia is required under the most-favoured-nation clause in its existing treaty with Korea (Rep.) to renegotiate the 1982 Australia-Korea (Rep.) treaty.
Expected changes – 2006
The first-time income and capital tax treaty between the Czech Republic and Korea (Dem. People's Rep.), signed on 2 March 2005, entered into force on 7 December 2005. The treaty generally applies from 1 January 2006.
Tax Court of Canada applies tie-breaker rules in CanadaKorea (Rep.) tax treaty to determine residence status
On 8 July 2005, Korea (Rep.) and Thailand initialled a revision to the Korea-Thailand income tax treaty of 26 August 1974. Further details are not yet available.
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