Article 11 - INTEREST - Republic of Korea [South Korea]
Extract
..... ph 2, interest arising in a Contracting State shall be exempt from tax in that State, provided that it is derived and beneficially owned by: a) the Government, a political sub-division or a local authority of the other Contracting State; or b) (i) in the case of India, the Reserve Bank of India, the Export-Import Bank of India or the National Housing Bank; and (ii) in the case of Korea, the Bank of Korea, the Export-Import Bank of Korea, the Korea Development Bank, the Korea Trade Insurance Corp .....
..... a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent .....