Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 13

Pursuant to the provisions in association with the term dividends under a DTA, where it illustrates that “the term dividends means income from shares or other rights, not being debt-claims, participating in profits,” it shall, in the case of the ROC, refer to the dividends distributed by a company or the surplus profits distributed by a cooperative, other juristic person, sole proprietorship, or partnership to its member, investor, sole proprietor, or partner. However, in the case that the applicable DTA provides otherwise, provisions thereof shall prevail.