The 74th OECD International Tax Seminars on Tax Treaties: Special Issues

June 11- 16, 2012 Hotel Prima, Seoul

□ The Tax Programme, OECD Korea Policy Centre (Director General: Seong-Dong Park, The     Korean Ministry of Strategy and Finance) hosted the 74th OECD International The Tax Semi-     nar on Tax Treaties: Special Issues for six days from June 11 (Mon.) to June 16 (Sat.), 2012     in Hotel Prima, Seoul, Korea.

□ Participants from countries in the Asia-Pacific region such as India, Chinese Taipei, Vietnam,     Mongolia, Philippines and etc. joined the event in order to strengthentheir capabilities to inter-     pret interpret Double Taxation Agreements and to enhance understandings on tax treaties     issues. The seminar was conducted through lectures, case studies and group discussions     on interpretation and application of detailed provisions based on the OECD Model Tax Con-     vention.

ㅇ Experts from OECD member countries (OECD Secretariat, New Zealand and Korea) and      China participated as lecturers and 18 tax officials from 13 non-OECD economies in the      Asia Pacific region (including three Korean tax officials from the NTS) joined the seminar.

Major discussions

□ Major issues dealt at the seminar are as follows;

ㅇ The role and operation of tax treaties

ㅇ Dual residence and beneficial ownership

ㅇ Principles of Permanent Establishment

ㅇ Interpretation of tax treaties, Immovable property and capital gains

ㅇ Dividend-interest, royalties

ㅇ Electronic commerce

□ In his opening speech, Director General of the Tax Programme, OECD/Korea Policy Centre,    Mr. Seong Dong Park encouraged participants and experts who came a long way to Korea    from Asia and Europe and went on to say that this seminar will be a big help in development    of tax systems and policies. He also asked participants to actively participate in discussions    on principles of tax treaties which will lead cooperation in tax field as well as prevent double    taxation and tax avoidance which can occur in international trades between countries.

□ Especially, mentioning the importance of tax treaties in the ever changing global economy,    Mr. Park emphasized that this seminar will be a practical foundation for interpretation and    application of tax treaties between countries.

□ Mr. David Partington, Principle Administrator, CTPA, OECD and experts from China and New    Zealand gave lectures on basic principles and application of tax treaties.

□ At the seminar, Mr. Jung Hong Kim, Director, Tax Programme, OECD/Korea Policy Centre    participated as an expert delivering lectures on interpretation of tax treaties.

□ The topic of this seminar, Tax Treaties mean all kinds of international agreements regulated     by international laws such as pacts, conventions, agreements and memorandum with ano-     ther country regarding taxation on income/capital or cooperation of tax administration. Tax     treaties may cover multilateral conventions as well as bilateral agreements on avoidance of     double taxation such as [Multilateral convention on Mutual administrative assistance] that EU,     OECD, OECD member economies and NOEs concluded.

At the Closing Ceremony,

□ At the closing ceremony on Friday, June 15th, 2012, Director General, Mr. Park praised ex-    perts for their hard work for the past five days who led the seminar successfully. He also ex-    pressed his appreciation to the participants who have joined the seminar sharing their own    experiences and information. Mr. Park also congratulated all the participants on becoming a    member of the KTC Family, Alumni Association of the KTC and wished everyone to have    good memories of Korea.

□ Director General, Mr. Seong Dong Park is granting a certificate to a participant from the Nepal    Inland Revenue Department.

□ After the certificate granting ceremony, Mr. Park took a commemorative photo with all the    participants and experts.

A chance to demonstrate outstanding features of Korea

□ After the seminar, participants' response to the social events such as a lecture on Korean    history & culture, Korean traditional musical performance, Seoul city tour and etc. were very    positive. It was a very good opportunity to demonstrate outstanding characteristics of Korean    history, culture and economic development considering that most of the participants visit    Korea for the first time.

□ Ms. Young Park, Communication Officer is giving a lecture on Korean history and culture.

□ Participants were able to experience development of Korean economy through the Seoul city    tour.

International tax cooperation

□ It is expected to have amicable relations when concluding a tax treaty by sharing information    on Korean tax treaty model inviting tax officials in charge of tax treaties and negotiations in each    each country.

ㅇIn case of Cambodia, they have no tax treaty up to now even though it is one of major eco-    nomies in Asia in terms of market entrance of Korean companies and trade volume. It is    highly expected that participants who have joined this event will be a representative at the    future negotiation and their participation in this event will be quite beneficial to us in relation    to the conclusion of tax treaties with them.

Tax Programme, OECD Korea Policy Centre