(1) With respect to interest, dividend, or royalty income out of the domestic source income of a foreign corporation under a tax treaty, the lower of a restrictive tax rate and any of the following tax rates shall apply:
1. Where a local income tax is not included in the taxes subject to a tax treaty: The tax rates prescribed in Article 98 (1) 1, 2, and 6;
2. Where a local income tax is included in the taxes subject to a tax treaty: A tax rate calculated by reflecting 10/100 of the corporate tax withheld under Article 103-52 (1) of the Local Tax Act at the tax rates prescribed in Article 98 (1) 1, 2 and 6.
(2) Notwithstanding paragraph (1), in cases falling under Article 98-5 (1), withholding tax shall be collected pursuant to the same paragraph. In such cases, where the tax base and tax amount are corrected pursuant to paragraph (3) of the same Article, the lower of a restrictive tax rate and the tax rate prescribed in any subparagraph of paragraph (1) shall apply.[This Article Added on Dec. 22, 2020]