Other income treated as taxable only in the resident State under the treaty's residual allocation. Other income not dealt with in preceding articles of the Korea tax treaty is subject solely to taxation by the resident Contracting State; the provision ... Summary
Other income treated as taxable only in the resident State under the treaty's residual allocation.
Other income not dealt with in preceding articles of the Korea tax treaty is subject solely to taxation by the resident Contracting State; the provision functions as a residual allocation rule conferring primary taxing rights to the State of residence and excluding source-State taxation for such unspecified income categories under the Convention.
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