Chile-Korea

2. Capital represented by movable property forming part of the business property of a permanentestablishment that an enterprise of a Contracting State has in the other Contracting State, or by movableproperty pertaining to a fixed base available to a resident of a Contracting State in the other ContractingState for the purpose of performing independent personal services, may be taxed in that other State.3. Capital represented by ships and aircraft operated in international traffic, and by movableproperty pertaining to the operation of such ships or aircraft, shall be taxable only in the ContractingState of which the enterprise operating such ships or aircraft is resident.4. All other elements of capital of a resident of a Contracting State shall be taxable only in thatState.CHAPTER VMETHODS FOR ELIMINATION OF DOUBLE TAXATIONArticle 23ELIMINATION OF DOUBLE TAXATION1. In Chile, double taxation shall, subject to the provisions of Chilean law regarding the eliminationof international double taxation (which shall not affect the general principle hereof), be eliminated asfollows:Residents in Chile, obtaining income which may in accordance with the provisions of thisConvention be subject to taxation in Korea, may credit the tax so paid against any Chilean tax payable inrespect of the same income; this paragraph shall apply to all income referred to in the Convention2. In Korea, double taxation shall, subject to the provisions of Korean law regarding the allowanceas credit against Korean tax of tax payable in any country other than Korea (which shall not affect thegeneral principle hereof), be eliminated as follows:(a) Where a resident of Korea derives income from Chile which may be taxed in Chile underthe laws of Chile in accordance with the provisions of this Convention, in respect of that income, theamount of Chilean tax payable shall be allowed as a credit against the Korean tax payable imposed onthat resident. The amount of credit shall not, however, exceed that part of Korean tax as computedbefore the credit is given, which is appropriate to that income;(b) Where the income derived from Chile is a dividend paid by a company which is aresident of Chile to a company which is a resident of Korea which owns not less than 10 per cent of thetotal shares issued by that company, the credit shall take into account the Chilean tax payable by thecompany in respect of the profits out of which such dividend is paid.3. Where in accordance with any provision of the Convention income derived or capital owned by aresident of a Contracting State is exempt from tax in that State, such State may nevertheless, incalculating the amount of tax on the remaining income or capital of such person, take into account theexempted income or capital.