□ 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 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