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HMRC internal manual

Double Taxation Relief Manual

Korea: Royalties

The agreement provides that the Korean tax on royalties paid to a United Kingdom resident is reduced to 2 per cent or 10 per cent. The terms of Article 12(2) should be consulted for details.

Cases where Korean tax has been deducted (and not repaid) from income which appears to fall within the terms of Article 7 (Business profits) and not Article 12 (Royalties) should be referred to Business International.