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HMRC internal manual

Double Taxation Relief Manual

Korea: Tax spared

Under Article 23 of the agreement, credit is given for tax `spared’ in Korea under Articles 14, 16, 24, 25 and 28 of the Korean Foreign Capital Inducement Law. See INTM161270 & 161280 and also INTM161290 for the reports required where credit is given for tax spared.

Relief is restricted to tax `spared’ in Korea for a period of ten years in respect of any one source of income and no credit for tax spared is due in respect of income or gains which arise or accrue after 31 December 2003.