Agreement Between the Government of the Russian Federation and the Government of the Democratic People's Republic of Korea for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital (Moscow, September 26, 1997)

• ARTICLE 1 Personal Scope

• 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 Profits from International Traffic

• ARTICLE 9 Associated Enterprises

• ARTICLE 10 Dividends

• ARTICLE 11 Interest

• ARTICLE 12 Royalties

• ARTICLE 13 Capital Gains

• ARTICLE 14 Income from Independent Personal Services

• ARTICLE 15 Income from Employment

• ARTICLE 16 Directors1 Fees

• ARTICLE 17 Income of Artists and Sportsmen

• ARTICLE 18 Pensions

• ARTICLE 19 Income from Government Service

• ARTICLE 20 Payments to Students, Trainees and Business Apprentices

• ARTICLE 21 Income of Professors, Teachers and Researchers

• ARTICLE 22 Other Income

• ARTICLE 23 Capital

• ARTICLE 24 Elimination of Double Taxation

• ARTICLE 25 Non-Discrimination

• ARTICLE 26 Mutual Agreement Procedure

• ARTICLE 27 Exchange of Information

• ARTICLE 28 Members of Diplomatic Missions and Consular Posts

• ARTICLE 29 Entry into Force

• ARTICLE 30 Termination

Authentic text

AGREEMENT
BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

Done at Moscow, on "26th" September of 1997 in duplicate, in Russian, Korean and English languages, all texts being equally authentic. In case of divergence in interpretation of the Russian and Korean texts the English text shall be the operative one.

FOR THE GOVERNMENT

OF THE RUSSIAN FEDERATION

(signature)

FOR THE GOVERNMENT OF

THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

(signature)