South Korea: Debt securities (except KGBs and MSBs) and Equities (Securities deposited with HSBC) – Change in relief at source procedure
Clearstream Banking1 informs clients that effective
immediately
the current relief at source procedure for South Korea debt securities (except KGBs and MSBs) and equities has been amended.
Background
Currently, Certificate of Residence (COR) must be submitted by beneficial owners that are:
- Tax exempt under the DTT such as Central banks, central and municipal government organisations, sovereign entities;
- Overseas Investment Vehicle “OIV” (non-public OIV) with tax exempt beneficial owners;
- Overseas Public Collective Investment Vehicle “OPCIV” (public OIV) with tax exempt beneficial owners;
- Overseas Investment Vehicle “OIV” (non-public) and Overseas Public Collective Investment Vehicle “OPCIV” (public OIV) treated as beneficial owner in accordance with the Corporate Tax Act;
- Malaysia investors.
With the change in procedure, all beneficial owners must submit a COR.
Impact on clients
As per the change in relief at source procedure, all types of beneficial owners must submit a COR for relief at source for South Korea debt securities (except KGBs and MSBs) and equities.
Further information
The Market Taxation Guide – South Korea – Debt securities (except KGBs and MSBs) and Equities (Securities deposited with HSBC) will be updated in due course.
For further information about procedures, clients may contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or their Relationship Officer.
------------------------------------------
1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG clients using Creation accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.
