China – South Korea Tax Treaty
The China-South Korea tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, and interest at 10%. Royalties are taxed at a uniform 10% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in China's network and one of 48 in South Korea's. The general dividend rate of 10% compares to a median of 10% across China's network and 15% across South Korea's.
Verified data
National Tax Service of Korea (nts.go.kr) - Tax Treaty rates and treaty texts (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: South Korea Treaty Reference| Income Type | Treaty Rate | Statutory Rate (South Korea) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 12% | 22% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 17% | 22% |
| Interest Bank interest, bonds, loans | 10%saves 12% | 22% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 10% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (South Korea)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 22%.
Source: South Korea Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 22% statutory rate. This represents a 12% reduction from the statutory rate.
Source: South Korea Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 10% to 10%.
Source: South Korea Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: South Korea Treaty Reference
Comparative Context
🇨🇳China's Network
Among China's 47 active treaty partners, the 10% general dividend rate ranks 23th (median: 10%).
| Partner | Rate |
|---|---|
| India | 10% |
| Italy | 10% |
| Japan | 10% |
| South Korea (this treaty) | 10% |
| Luxembourg | 10% |
| Mexico | 10% |
| Malaysia | 10% |
🇰🇷South Korea's Network
Among South Korea's 48 active treaty partners, the 10% general dividend rate ranks 4th (median: 15%).
| Partner | Rate |
|---|---|
| Brazil | 0% |
| United Arab Emirates | 10% |
| Chile | 10% |
| China (this treaty) | 10% |
| Colombia | 10% |
| Czech Republic | 10% |
| Greece | 10% |