Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 29

Where a resident of the other Contracting State derives income from performing professional services or other activities of an independent character within the territory of the ROC which is subject to income tax according to the provisions in association with the term independent personal services under a DTA, the taxable income may be determined by the deduction of relevant costs and expenses from the remuneration of such services or activities, if the relevant accounting books or documents of evidence can be provided in accordance with the stipulations of the Income Tax Act and relevant laws or regulations.In the case that the aforementioned professional services or other activities of an independent character are partially rendered outside the territory of the ROC, the resident of the other Contracting State may apply with the tax collection authority where the payer of such income is located to be taxed only on the income derived from services or activities rendered within the territory of the ROC, if the relevant contracts and documents pertaining to the calculation of the income can be provided.