Tax Collection Act Article 5

The MOF may, based on the principle of reciprocity, enter into a reciprocal tax exemption treaty with a foreign government and put it into force after having obtained the approval of the Executive Yuan thereon and completing the formality of exchange of diplomatic instruments with the foreign government.
中文原文 稅捐稽徵法第5條
財政部得本互惠原則,與外國政府商訂互免稅捐,於報經行政院核准後,以外交換文方式行之。

English translation for reference only; the Chinese text prevails. Not legal advice.