Print Edition
September 2010 
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The Increased Emphasis On Beneficial Ownership Analysis In Determining Eligibility Of Offshore Income Recipients To Claim Tax Treaty Benefits |
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Mee-Hyon Lee, August 2010 |
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Many of the tax treaties for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes to which Korea is a party (collectively the ‘Tax Treaties’ and singly a ‘Tax Treaty’) do not contain any express provisions concerning the requirement of beneficial ownership to clarify how the Tax Treaty is to be applied with respect to payments made to intermediaries. more...
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