ARTICLE 11
Dividends
1. Dividends paid by a corporation of one of the Contracting States to a resident or corporation of the other Contracting State may be taxed in that Contracting State, but the tax shall not exceed: (a) 20 per cent of the gross amount of dividends if the corporation paying the dividends engages in an industrial undertaking or if the recipient of the dividends is a corporation of the other Contracting State owning at least 25 per cent of the voting stock of the corporation paying the dividends; (b) 15 per cent of the gross amount of dividends if the corporation paying the dividends engages in an industrial undertaking and the recipient of the dividends is a corporation of the other contracting State owning at least 10 per cent of the voting stock of the corporation paying the dividends. 2. The provisions of paragraph (1) of this Article shall not apply if the recipient of the dividends, being a resident of corporation of one of the Contracting States,has in the other Contracting State in which the dividends arise a permanent establishment with which the holding by virtue of which the dividends are paid is effectively connected. In such a case, the provisions of Article 7 shall apply, as if they were industrial or commercial profits. 3. Where a corporation of one of the Contracting States derives profit or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the corporation to persons other than a resident or corporation of that other State, or any tax in the nature of undistributed profits tax on undistributed profits of the corporation, whether or not those dividends or undistributed profits represent, in whole or in part, profits or income so derived. 4. In this Article, the term "industrial undertaking" means an undertaking falling under any of the classes mentioned below: (a) Manufacturing, assembling and processing; (b) construction, civil engineering and shipbuilding; (c) production of electricity, hydraulic power or gas or the supply of water; (d) agriculture, forestry and fishery and carrying on of a plantation; (e) any other undertaking entitled to the privileges accorded under the laws of either Contracting State on the promotion of industrial investment; and (f) any other undertaking which may be declared to be an industrial undertaking for the purposes of this Article by the competent authority of the Contracting State in which the undertaking is situated. ARTICLE 12
Interest 1. Interest derived from sources within one of the Contracting States by the Government of the other Contracting State including local authorities thereof, the central bank of that other Contracting State, or any agency or instrumentality (including financial institution) wholly owned by that Government or that central bank or by both, shall be exempt from tax in the first-mentioned Contracting State. 2. The tax imposed by one of the Contracting States on interest received by any financial institution (including an insurance company) which is a corporation of the other Contracting State on debentures issued by, or on loans made to, a resident or corporation of the former Contracting State shall not exceed 10 per cent of the gross amount thereof. 3. The provisions of paragraph (2) of this Article shall not apply if the recipient of the interest, being a resident or corporation of one of the Contracting States, has in the other Contracting State in which the interest arises a permanent establishment with which the debt claim from which the interest arises is effectively connected. In such a case, the provisions of Article 7 shall apply, as if it were industrial or commercial profits. 4. Where any interest paid by a person to any related person, as defined in Article 10, exceeds a fair and reasonable consideration in respect of the indebtedness for which it is paid, the provisions of paragraph (2) of this Article shall apply only to so much of the interest as represents such fair and reasonable consideration; and the excess payment shall be characterized and taxed according to the laws of each Contracting State, including the provisions of this Convention where applicable. 5. (a) Except as provided in subparagraph (b), interest paid by one of the Contracting States, including any local Government thereof, or by a resident or corporation of that Contracting State shall be treated as income from sources within that Contracting State. (b) Interest paid by a resident or corporation of any State with a permanent establishment in another State directly out of the funds of such permanent establishment on indebtedness incurred for the sole use of, or on banking deposits made with, such permanent establishment shall be treated as income from sources within the State in which such permanent establishment is located. ARTICLE 13
Royalties 1. The tax imposed by one of the Contracting States on royalties derived from sources within that Contracting State, and on income derived from sources within that Contracting State from alienation of the property or information described in paragraph (2) of this Article, by a resident or corporation of the other Contracting State not having a permanent establishment in the former Contracting State shall not exceed 15 per cent of the gross amount thereof. 2. For the purposes of this Article, the term "royalties" means any royalties, rentals or other amounts paid as consideration for the use of, or the right to use; (a) copyrights of literary, artistic or scientific works, patents, designs, plans secret processes or formula, trade marks, motion picture films, films or tapes for radio or television broadcasting, or other like property or right, or (b) information concerning industrial, commercial or scientific knowledge, experience, or skill. The term does not include any royalties, rentals or other amounts paid in respect of the operation of mines, quarries or other natural resources. 3. The provisions of paragraph (1) of this Article shall not apply if the recipient of the royalties or income, being a resident or corporation of one of the Contracting States, has in the other Contracting State in which the royalties or income arise a permanent establishment with which the property, right or information giving rise to the royalties or income is effectively connected. In such a case, the provisions of Article 7 shall apply, as if the royalties or income were industrial or commercial profits. 4. Where any royalties paid by a person to any related persons, as defined in Article 10, exceeds a fair and reasonable consideration in respect of the rights for which it is paid, the provisions of paragraph (1) of this Article shall apply only to so much of the royalty as represents such fair and reasonable consideration; and the excess payment shall be characterized and taxed according to the laws of each Contracting State, including the provisions of this Convention where applicable. 5. Royalties paid for the use of, or the right to use, property or information described in paragraph (2) of this Article in one of the Contracting states shall be treated as income from sources within that State. Income from alienation of property ori nformation described in paragraph (2) of this Article for use in one of the Contracting States shall be treated as income from sources within that State. ARTICLE 14
Income from Immovable Property Incom from immovable property, including gains derived from the sale or exchange of such property, or royalties in respect of the operation of mines, quarries, or other natural resources may be taxed in the Contracting State in which such immovable property is located. Ships and aircraft shall not be regarded as immovable property. ARTICLE 15
Income from Personal Services 1. Income from personal services derived by a resident of one of the Contracting States in respect of the services rendered in the other Contracting State Shall be exempt from tax by the other Contracting State if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and (b) the income is paid by, or on behalf of, a person other than resident or corporation of the other State, and (c) the income is not borne by a permanent establishment which the person paying the income has in the other State. 2. For purposes of paragraph (1), the term "income from personal services" includes employment income and income earned by an individual from the performance of personal services in an independent capacity. The term "employment income" includes income from services performed by officers and directors of corperation, but doesd not include income from personal services performed by partners which shall be treated as income from the performance of services in an independent capacity. 3. Notwithstanding the provisions of paragraph (1) and (2) of this Article, the income received by an individual in his capacity as a member of the board of directors of a corporation of one of the Contracting States may be taxed in that Contracting State. 4. Notwithstanding the provisions of paragraph (1) of this Article, income from personal service performed aboard ships or aircraft operated by a resident or corporation of the one of the Contracting States shall be exempt from tax in the Other Contracting State. 5. Notwithstanding paragraph (1) of this Article, the income from personal services of public entertainers, suich as athletes, musicians and actors, from their activities as such, may be taxed in the Contracting State in which the services are performed if such income exceeds either 50 US dollars (or its equivalent in Korean Won or Thai Baht) for each day the individual is present in the latter Contracting State or an aggregate amount of 1,500 US dollars (or it equivalent in Korean Won or Thai Baht). | 
