Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 37

Where a resident of the ROC seeks to obtain a foreign tax credit for the amount of tax that has been spared in the other Contracting State pursuant to the tax sparing provisions in association with the term elimination of double taxation under a DTA, that resident shall, while filing the annual income tax return, provide a certificate issued by the tax authority of the other Contracting State which contains information of the applicable laws for the reduction of or exemption from tax, the amount of income, and the amount of the tax reduction or exemption, etc.The obtaining of a foreign tax credit for tax that has been spared in the other Contracting State referred to in the preceding paragraph shall not include the foreign tax credits granted by the DTA between that other Contracting State and a third party.