korean-tax-mcp

Royalties paid to a US parent: withholding tax under the Korea–US treaty

Question: “Our Korean subsidiary pays KRW 100 million of royalties to its US parent in 2026. How much Korean withholding tax applies under the Korea–US tax treaty, and is local income tax on top?”

Tools

Step Server Tool Why
1 korean-tax-mcp treaty_withholding_rates treaty cap on royalties, with the clause text and whether the treaty covers Korean local income tax
2 korean-tax-mcp tax_treaty (optional) read the whole royalties article and related documents
3 korean-tax-calc-mcp nonresident_withholding withholding amount = lower of the domestic rate and the treaty cap, plus local income tax
4 korean-tax-mcp search_tax_rulings, get_tax_ruling (optional) if the payment is for software or know-how, check whether it is a royalty at all

1. Treaty cap

{"tool": "treaty_withholding_rates", "arguments": {"country": "미국", "income": "royalties", "lang": "en"}}

Result outline (0.15.1):

2. Withholding amount

Industrial royalty, 15% treaty cap:

{"tool": "nonresident_withholding", "arguments": {"income_kind": "사용료", "amount": 100000000, "recipient_type": "법인", "residence_country": "US", "treaty_rate": 0.15, "year": 2026}}
Field Result
Domestic rate 20%
Treaty rate 15%
Applied rate 15%
Withholding tax KRW 15,000,000
Local income tax KRW 1,500,000
Total KRW 16,500,000
Basis Corporate Tax Act Art. 98(1)6; treaty cap 15%; treaty does not cover local income tax

Without the treaty rate (for example, if the application for the reduced rate was not filed), the same call without treaty_rate gives 20%: KRW 20,000,000 plus KRW 2,000,000 local income tax.

The tool also flags issues to check:

What the agent should answer

Not tax advice. Verify against the treaty text, the statute in force on the payment date and the rulings cited.

All use cases