Recently, I changed my long-standing Apple Developer account from an individual to a corporate entity. This process was not as difficult as I thought, and unlike in the past, I was able to obtain a D-U-N-S number for free through the Apple Developer account site, and I was able to proceed easily through a few processes and inquiries.

However, after changing the account type and entering account information and performing a few additional tasks, I struggled to find clear information while filling out the W-8BEN-E. Based on my troubleshooting, I will summarize a few things.

What is W-8BEN-E?

W-8BEN-E is a document that allows a foreign corporation to prove it is not a U.S. corporation and receive tax benefits when receiving income in the U.S. The general income tax rate in the U.S. is 35%, but a foreign corporation only needs to pay 30% in Withholding Tax. This rate can be lowered to 0% depending on the tax agreement between the U.S. and that country. Korean companies can receive Withholding Tax exemption benefits by submitting a W-8BEN-E according to the U.S.-Korea income tax treaty.

For individuals, you simply need to enter the W-8BEN to use the service. This is common when earning revenue through Google's YouTube or applying for other similar revenue structures, so you are likely familiar with it. Since the relevant form sections are clearly displayed, the process is not very difficult.

However, since the W-8BEN-E is a form for corporations rather than individuals, I couldn't find proper information even after searching, and when I contacted Apple, they directed me to discuss it with an accountant or tax advisor. So, when I spoke with the tax advisor I had contracted, they said they found it difficult to answer because it was an unfamiliar form.

It is understandable that this feels unfamiliar... The original W-8BEN-E form was provided as a PDF, requiring printing, handwritten signature, and submission via Fax. However, since the widespread adoption of electronic signatures following the COVID-19 pandemic, Apple has started providing an Apple form that allows users to fill it out directly. Ironically, this change in structure makes it feel unfamiliar.

Below is what the W-8BEN-E looks like in Apple's contract screen.

It might look difficult, right?

So I consulted with my contracted accountant and, with the help of a friend who is a U.S. lawyer, I was able to organize and verify the content through Google. Interestingly, I found a site that had well-organized relevant information.

For users or companies wishing to receive payments for sharing photos or image assets directly on the Shutterstock site, it is explained very well.

https://support.submit.shutterstock.com/s/article/How-do-I-submit-a-W-8BEN-E-tax-form

Additionally, there was an answer regarding this question on the AI consultation response board of the Korean Anti-Corruption and Civil Rights Commission, so I was able to reference it.

https://www.kita.net/tradePro/aiConsult/aiConsultServiceDetail.do?aiNo=77942&pblcConsultId=1062

In summary, to avoid paying a high 30% tax when receiving revenue deposits from the Apple App Store for business owners or corporate entities conducting revenue activities only within Korea, you must complete and submit the W-8BEN-E (for individuals or sole proprietors, the W-8BEN) available in the Apple Developer Console to report a 0% tax rate.

This can be supported by referencing the relevant details in the IRS document regarding the U.S.-Korea tax treaty.

https://www.irs.gov/pub/irs-trty/korea.pdf

In the document, looking at question 1 of article 8, it reads as follows.

To translate this

" (1) The industrial or commercial profits of a resident of one of the Contracting States shall not be taxed in the other Contracting State unless such profits are derived through a permanent establishment situated therein. If such profits are derived through a permanent establishment, the other Contracting State may tax such profits, but only so far as may be attributable to that permanent establishment. "

According to this, for our corporation developing apps in Korea, the content indicates that we are exempt from taxes.

Therefore, in the Apple Developer Console, you can enter the following for that item.

Then, as confirmed above, enter the justification for 0%. Check that the revenue is from applications in the sales history.

Finally, check the certification section in Part XXX.

With that, I have shared how I struggled the most with filling out the W-8BEN-E while switching my Apple Developer account to a corporate entity this time.

Please consult with a tax professional, accounting professional, or legal professional with whom you have a contract as much as possible.

Thank you.