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Germany – Republic of Korea · Source editionArticle 11 Interest

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(1)

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

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(2)

2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.

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(3)

3. Notwithstanding the provisions of paragraph 2, (a) interest arising in the Federal Republic of Germany, a Land, a political subdivision or a local authority thereof and paid to the Republic of Korea, the Bank of Korea, the Korea Export- Import Bank, the Korea Development Bank and similar finan- cial institutions as may be specified by mutual agreement between the competent authorities of the Contracting States as well as interest paid in consideration of a loan guaranteed by the Korea Export Insurance Corporation shall be exempt from German tax; (b) interest arising in the Republic of Korea and paid to the Fed- eral Republic of Germany, the Deutsche Bundesbank, the Kreditanstalt für Wiederaufbau or the Deutsche Finanzie- rungsgesellschaft für Beteiligungen in Entwicklungsländern and similar financial institutions as may be specified by mutu- al agreement between the competent authorities of the Con- tracting States as well as interest paid in consideration of a loan guaranteed by HERMES-Deckung shall be exempt from Korean tax.

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(4)

4. Notwithstanding the provisions of paragraph 2, interest as defined in paragraph 1 may be taxed only in the Contracting State of which the recipient is a resident if the recipient is the beneficial owner of the interest and the interest is paid (a) in connection with the sale of commercial or scientific equip- ment on credit, or (b) in connection with the sale of goods by an enterprise to another enterprise on credit.

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(5)

5. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mort- gage and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including pre- miums and prizes attaching to such securities, bonds or deben- tures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. However, the term “inter- est” shall not include income dealt with in Article 10.

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(6)

6. The provisions of paragraphs 1, 2 and 4 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal ser- vices from 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.

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(7)

7. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a Land, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Con- tracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

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(8)

8. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest exceeds, for what- ever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such rela- tionship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the pay- ments shall remain taxable according to the laws of each Con- tracting State, due regard being had to the other provisions of this Agreement.

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Source, edition and limits
Source edition
de-republic-of-korea-2002-base | BGBl. 2002 II S. 1630 | signed 2000-03-10 | published 2002-07-16 | Signed: 2000-03-10 | Gazette publication: 2002-07-16
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Korean as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-republic-of-korea-2002-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2000-03-10; consent law 2002-07-10; gazette publication 2002-07-16. Edition ID year is not a signature date. Treaty entry into force: 2002-10-31. Roster general application: 2003-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 31. Oktober 2002. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Korea, Republik R-P P: 18.04.2018 KR KR. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Text language and status
en · authentic-language-transcription · machine-transcription
Citation
BGBl. 2002 II S. 1630
SHA-256
19f6479f55148cfad9a36af88630425d9315c80acdcddf12ea9ea89ab2fae385

Citation

Copyable citation

BGBl. 2002 II S. 1630 | de-republic-of-korea-2002-base | de-republic-of-korea-2002-base | BGBl. 2002 II S. 1630 | signed 2000-03-10 | published 2002-07-16 | Signed: 2000-03-10 | Gazette publication: 2002-07-16 | Article 11 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-republic-of-korea-2002-base/en/articles/article-11/

Disclaimers

Language switching retains matching article and paragraph identifiers. The mapping does not confirm reviewed legal or translational equivalence.

BGBl. 2002 II S. 1630

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Source details · Preamble and protocol

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