Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 2

The investigation and audit of a case applicable under an agreement for the avoidance of double taxation with respect to taxes on income (hereinafter referred to as the “DTA”) shall be conducted in accordance with the provisions of the DTA signed between a country or territory and the Republic of China (hereinafter referred to as the “ROC”). Any such matter not provided for in the DTA shall be governed by the stipulations of the Taxpayer Rights Protection Act, the Tax Collection Act, the Income Tax Act, the Income Basic Tax Act, these Regulations, and relevant laws and regulations. However, where the stipulations of the Income Tax Act or other laws providing reduction of or exemption from income tax that are more favorable than those contained in the provisions under the DTA, the most favorable provisions shall apply.