한국어 학습자들이 '식물이 자라지 않은 땅'과 '식물이 자라지 않는 땅'의 차이를 이해하기 어렵나요?

I have come to realize that the difference between '-은/-는' can change the meaning while learning Korean. For example, there are expressions like 'the land where plants do not grow' and 'the land where plants are not growing.' Although the two sentences seem similar, there is a subtle difference in meaning. Native Korean speakers naturally use these grammatical elements, but for Korean learners, these differences can be difficult to understand at first. I also didn't understand these differences well at first, but I became aware of them while writing. Do foreign learners of Korean find it difficult to understand these differences? Or if you have tips on how to better understand these points, please share!