[Title] Protocol, Convention between the Republic of Korea and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income.

At the signing of the Convention between the Republic of Korea and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (hereinafter referred to as “the Convention”), the undersigned have agreed upon the following provisions which shall form an integral part of the Convention:

1. Notwithstanding the provisions of sub-paragraph (a) of paragraph 2 of Article 10 of the Convention, the tax charged under the said sub-paragraph shall not exceed 10 per cent of the gross amount of the dividends until December 31, 2003.

2. Notwithstanding the provisions of sub-paragraph (a) of paragraph 1 of Article 17 of the Convention, income derived by an individual who is a resident of a Contracting State from his personal activities exercised in the other Contracting State shall be exempt in that other Contracting State if such income does not exceed an aggregate amount of 10,000 United States dollars or its equivalent in Korean Won or Japanese Yen during any calendar year.

3. The benefits of the Convention shall not apply if the competent authorities of the Contracting States agree that the taking advantage of those provisions constitutes an abuse of the provisions of the Convention.

In Witness Whereof, the undersigned, being duly authorised thereto by their respective Governments, have signed this Protocol.

Done in duplicate at Tokyo this eighth day of October, 1998, in the English language.

For The Government of The Republic of Korea:

HONG SOON-YOUNG

For The Government of Japan:

MASAHIKO KOUMURA