Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 27

Where a resident of the other Contracting State derives income from ROC sources, other than those provided in the preceding four articles, and is entitled to a reduction of or exemption from tax in accordance with the provisions of a DTA, that resident shall provide a Certificate of Residence issued by the tax authority of the other Contracting State along with other relevant documents in connection with such income, and apply to the tax collection authority where the payer of such income is located for approval. Where the income is subject to withholding tax under Article 88 of the Income Tax Act, the tax collection authority shall, when issuing the approval, simultaneously notify the tax withholder of the reduction of or exemption from the withholding tax.When, in accordance with the stipulations of the Income Tax Act, the resident of the other Contracting State referred to in the preceding paragraph is required to file the annual income tax return or file a tax return and make tax payment, such resident may submit the documents specified in the preceding paragraph while filing the annual income tax return or filing a tax return and making tax payment to concurrently apply for the application of a DTA. The tax collection authority shall determine the amount of income which is entitled to the reduction of or exemption from such tax.