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1. This Agreement shall apply to taxes on income and on capi- tal imposed on behalf of a Contracting State, of a Land or a politi- cal subdivision or local authority thereof, irrespective of the man- ner in which they are levied.
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2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on el- ements of income or of capital, including taxes on gains from the alienation of movable or immovable property, the payroll tax, and taxes on capital appreciation.
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3. The existing taxes to which this Agreement shall apply are in particular: (a) in the Federal Republic of Germany: the income tax (Einkommensteuer), the corporation tax (Körperschaftsteuer), the capital tax (Vermögensteuer), and the trade tax (Gewerbesteuer) including the supplements levied thereon (hereinafter referred to as “German tax”); (b) in the Republic of Korea: the income tax, the corporation tax, the special tax for rural development surcharged directly or indirectly on the tax base of the income tax or the corporation tax, and the local inhabitant tax surcharged on the income tax or the corporation tax (hereinafter referred to as “Korean tax”).
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4. The Agreement shall apply also to any identical or substan- tially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.