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ARTICLE 18

U.S. Income Tax Treaty — Korea Income Tax Treaty - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States

Independent Personal Services

(1) Income derived by an individual who is a resident of one of the Contracting States from the performance of personal services in an independent capacity, may be taxed by that Contracting State. Except as provided in paragraph (2), such income shall be exempt from tax by the other Contracting State.

(2) Income derived by an individual who is a resident of one of the Contracting States from the performance of personal services in an independent capacity in the other Contracting State may be taxed by that other Contracting State, if:

(a) The individual is present in that other Contracting State for a period or periods aggregating 183 days or more in the taxable year;

(b) Such income exceeds 3,000 United States dollars or its equivalent in Korean won in a taxable year; or

(c) The individual maintains a fixed base in that other Contracting State for a period or periods aggregating 183 days or more in the taxable year, but only so much of his income as is attributable to such fixed base.

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▸Contents — U.S. Income Tax Treaty — Korea Income Tax Treaty - 1976
U.S. Income Tax Treaty — Korea Income Tax Treaty - 1976

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