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of <h1>India-South Korea Protocol on Double Taxation: Key Provisions on Capital Gains and Non-Discrimination Explained.</h1> The Protocol forms part of the Double Taxation Avoidance Agreement between India and South Korea, addressing capital gains and non-discrimination. For Article 13, 'shares of the capital stock' refers to shares deriving over 50% of their value from immovable property. Regarding Article 24, India may tax profits of a Korean company's permanent establishment at a higher rate than similar Indian companies, while Korea may impose an additional tax on profits of an Indian company's permanent establishment, not exceeding 15% after deductions. This Protocol, signed on May 18, 2015, in Seoul, is equally authentic in Hindi, Korean, and English, with the English text prevailing in case of interpretation issues.
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