Act Governing Relations between the People of the Taiwan Area and the Mainland Area Article 24

Any individual, juristic person, organization, or other institution of the Taiwan Area having income derived from sources in the Mainland Area shall pay income tax thereon together with the income derived from sources in the Taiwan Area; provided, however, that the amount of the income tax already paid in the Mainland Area may be deducted from the amount of the income tax payable.Where any juristic person, organization, or other institution of the Taiwan Area permitted by the competent authorities in accordance with the provisions of Article 35 to make any investment in the Mainland Area through the company or enterprise it establishes in any third area includes in its tax return the investment income of its company or enterprise in the third area according to the Income Tax Act, the investment income of such company or enterprise derived from the income distributed by the invested company or enterprise in the Mainland Area shall be deemed the income derived from sources in the Mainland Area and taxed according to the preceding paragraph; provided, however, that the amount of income tax paid in the Mainland Area and the third Area against the portion of investment income derived from sources in the Mainland Area may be deducted from the amount of the income tax payable.The total amount to be credited in accordance with the preceding two paragraphs may not exceed the increment of the income tax payable computed, after including the income derived from sources in the Mainland Area, at the applicable tax rate of the Taiwan Area.