NOTES OF EXCHANGE TO THE CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND THE REPUBLIC OF KOREA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND THE ENCOURAGEMENT OF INTERNATIONAL TRADE AND INVESTMENT EMBASSY OF THE UNITED STATES OF AMERICA Seoul, June 4, 1976 No.152 His Excellency PARK TONG-JIN, Minister of Foreign Affairs, Seoul. 　　EXCELLENCY: I have the honor to refer to the Income Tax Convention signed between the Governments of Korea and the United States. During the course of the negotiations leading up to the signed Convention, the Korean representatives (A) stressed the need for increased provisions in the Convention that would constitute special incentives to promote the flow of United States capital and technology to Korea and (B) stated that the Convention applies to the Korean Defense Tax imposed in connection with the taxes referred to in Article 1(1) of the Convention. 　　The United States delegation was unable to agree to provisions for special investment incentives, but I want to assure you that my Government recognizes the importance which your Government places on increased investment in Korea. Accordingly, when circumstances permit, my Government will be prepared to resume discussions with a view to incorporating provisions into this Convention that will minimize the interference of the United States tax system with incentives offered by the Government of the Republic of Korea and that will be consistent with the income tax policies of the United States Government regarding other developing countries. 　　I should appreciate your confirmation that the Government of the Republic of Korea interprets the words "Korean Tax" in Article 1 (1) as including the Korean Defense Tax assessed on the taxes referred to therein. 　　Accept, Excellency, the renewed assurances of my highest consideration. 　　　　　　　　　　　　　　　　　　　　　　　　　RICHARD L. SNEIDER 　　I, the undersigned Foreign Service Officer of the United States of America, duly commissioned and qualified, do hereby certify that this document is a true and faithful copy of the original signed by Richard L. Sneider. GORDAN J. DUGAN. MINISTRY OF FOREIGN AFFAIRS Seoul, June 4, 1976. His Excellency RICHARD L. SNEIDER, Ambassador Extraordinary and Plenipotentiary of the United States of America to the Republic of Korea. 　　EXCELLENCY: I have the honor to acknowledge the receipt of your Excellency's Note dated June 4, 1976 with regard to increased investment of the United States in Korea and with regard to the application of the Tax Convention to the Korean Defense Tax imposed in connection with the taxes referred to in Article 1(1) of the Convention. 　　I have further the honor to note that the United States will be prepared, when circumstances permit, to resume discussions with a view to incorporating provisions into the Convention that will minimize the interference of the U.S. tax system with incentives offered by the Government of Korea and that will be consistent with the income tax policies of the United States Government regarding other developing countries. 　　I also have the honor to confirm that the definition of Korean tax in Article 1 (1) of the Tax Convention includes the Korean Defense Tax assessed on the taxes referred to therein. 　　Accept, Excellency, the renewed assurances of my highest consideration. 　　　　　　　　　　　　　　　　　　　　　　　　　　　　　T. JIN PARK 　　　　　　　　　　　　　　　　　　　　　　Minister of Foreign Affairs