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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Source of income

For the purposes of the Elimination of double taxation Article , profits, income and capital gains owned by a resident of the United Kingdom which may be taxed in Korea under the provisions of the agreements are deemed to be income or capital gains from sources in Korea (Article 23(3) of the agreement).

Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(7)and 12(5)).