The 69^th OECD Tax Seminar on "Tax Treaties: Special Issues"

(2011. 4.11 ~ 16, Noblesse A Hall, Prima Hotel)

 □ The Tax Programme hosted the 69thOECD International Tax Seminar on Tax Treaties: Special

     Issues for six days from April 11 (Monday) to 16 (Saturday), 2011& in Noblesse A Hall, Prima

     Hotel (Located in Cheongdam-dong, Gangnam-gu).

 □ Mr. David Partington, Principal Administrator of the CTPA, OECD participated in the seminar as a course  

     leader and 20 tax officials from 13 non-OECD economies including three Korean participants from

     the National Tax Service.

    ㅇ Mr. Graham Clark of the  IRS, U.S.A. was scheduled to attend the seminar but he could not join due to

        the internal affairs so all the sessions in the seminar were carried out by Mr. Partington.

 Main Contents

 □ The main contents which were discussed in the seminar are as follows:

     ㅇ The role and operation of tax treaties

     ㅇ Entitlement to treaty benefits and dual residence

     ㅇ Definition and basic rules of permanent establishment

     ㅇ Interpretation and application of tax treaties

     ㅇ Problems and solutions of double taxation related to construction activities and agents

     ㅇ Profits attributable to permanent establishments

     ㅇ Immovable property and capital gains, tax treaties

     ㅇ Imposing a tax on electronic commerce

     ㅇ Definition of royalties

     ㅇ Taxation on artists and sportmen

   ㅇ Basic international taxation theories such as OECD Taxation Model and cases were presented followed 

       by a group discussion and presentation to share information on the current conditions of tax treaties

       in each country, and differences among them.

 Study Tour to Seoul Tower, Samsung Electronics and Other Historical Sites

 □ All the participants had an opportunity to see attractions in Seoul such as Seoul Tower, and

     Gwanghwamun Square.

      ㅇ Participants also visited Samsung Electronics (Seoul) and experienced Korea’s IT development.