https://www.taxtmi.com/acts?id=5032 Taxation of interest under the Korea DTAA permits the recipient's State to tax interest but allows source-state taxation subject to withholding limits for the beneficial owner; banks and certain public institutions receive preferential or exempt source treatment. The Article broadly defines interest as income from debt-claims and provides that treaty withholding limits do not apply when interest is effectively connected to a permanent establishment or fixed base, in which case business profits or personal services rules apply. is deemed to arise in the payer's State or, if borne by a permanent establishment or fixed base, in the State where that establishment or base is situated. Special-relationship adjustments limit treaty application to arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 16:21:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5032 Taxation of interest under the Korea DTAA permits the recipient's State to tax interest but allows source-state taxation subject to withholding limits for the beneficial owner; banks and certain public institutions receive preferential or exempt source treatment. The Article broadly defines interest as income from debt-claims and provides that treaty withholding limits do not apply when interest is effectively connected to a permanent establishment or fixed base, in which case business profits or personal services rules apply. is deemed to arise in the payer's State or, if borne by a permanent establishment or fixed base, in the State where that establishment or base is situated. Special-relationship adjustments limit treaty application to arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5032