Emerging Markets Rates and Currencies Handbook

Tax Summary – South Korea Korea Taxes/Duties Comments • MOEF report is required for over US$30mm financing in cumulative basis within last 12 months • 15.4% WHT (includes 10% surtax on the 14% base rate) for interest on bonds issued by the State, local government and a domestic corporation. Effective Jan 1, 2023, in case where non-resident individuals or foreign corporations invest into KTB (Korea Treasury Bond) or MSB (Monetary Stabilization Bond), the coupon/accrued interest & capital gains, if any, are eligible for tax exemption in Korea, resulting in no WHT when paid. • A lower rate on treaty countries generally applies if the beneficial • owner of the dividends is a company with a substantial ownership (typically 25%; depending on country) in the dividend paying company Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor Source: Relevant legislation, publicly available sources Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing