Enforcement Rules of the Income Tax Act Article 8-1
Exemption of profit-seeking enterprise income tax for foreign international transportation enterprises in accordance with Subparagraph 20, Paragraph 1, Article 4 of the Act is limited to the cases where there is a reciprocal tax exemption clause in the tax treaty signed with the R.O.C. government or there is consent to reciprocal tax exemption by exchange of diplomatic letters, and where the Ministry of Finance has approved the practice of such tax exemption.
中文原文 所得稅法施行細則第8-1條
外國國際運輸事業依本法第四條第一項第二十款免徵營利事業所得稅，以與我國政府簽訂之租稅協定中訂有互惠免稅條款或經外交換文同意互惠免稅，經財政部核定實施者為限。