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June 26, 2026

This bilateral Convention between the United Arab Emirates and the Republic of Korea establishes a comprehensive tax framework for the elimination of double taxation and the prevention of tax evasion and avoidance on income. Replacing their 2003 treaty, it defines Permanent Establishment thresholds at 12 months for both construction projects and the furnishing of services. The treaty caps withholding tax on dividends at 5% for substantial corporate holdings (at least 10% capital) and 10% in all other cases, while interest and royalties are capped at 10%. Furthermore, it grants mutual tax exemptions for sovereign wealth funds, specifies recognized stock exchanges, and outlines strict 'Entitlement to Benefits' criteria to mitigate treaty-shopping risks.

Convention between the UNITED ARAB EMIRATES and the REPUBLIC OF KOREA for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance

StatusIn Force

Signed on27 February 2019

Entered into force19 December 2019

Amended on-

Terminated on-

The United Arab Emirates and the Republic of Korea,

Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,

Intending to conclude a Convention for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Convention for the indirect benefit of residents of third States),

Have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Dependent Personal Services

Article 15 - Directors' Fees

Article 16 - Entertainers and Sportspersons

Article 17 - Pensions and Annuities

Article 18 - Government Service

Article 19 - Students

Article 20 - Other Income

Article 21 - Elimination of Double Taxation

Article 22 - Non-Discrimination

Article 23 - Mutual Agreement Procedure

Article 24 - Exchange of Information

Article 25 - Members of Diplomatic Missions and Consular Posts

Article 26 - Entitlement to Benefits

Article 27 - Miscellaneous Rules

Article 28 - Entry into Force

Article 29 - Termination

Protocol

Article 1
Persons Covered

This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

This is an unofficial / best effort translation

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered