Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 16
Pursuant to the provisions in association with the term independent personal services under a DTA, where a resident of the other Contracting State for the purpose of performing professional services or other activities of an independent character has a fixed base within the territory of the ROC, and based on which that resident of the other Contracting State is subject to income tax, the determination of that resident of the other Contracting State to have a fixed base in the ROC shall accord with the provisions of Paragraph 2, Article 7 of these Regulations, mutatis mutandis.
中文原文 適用所得稅協定查核準則第16條
依所得稅協定有關執行業務之規定，他方締約國之居住者因執行業務或其他具有獨立性質活動，在中華民國境內有固定處所，應課徵所得稅者，其固定處所之認定，準用第七條第二項規定。