[Taxation] ROC Tax Treaty Policy

The ROC's general policy toward tax treaties is to avoid double taxation, prevent fiscal evasion and strengthen substantive relations. The tax treaties that the ROC has entered into follow the OECD model and take into consideration matters relating to the political and fiscal status, economics, and trade of the mutual parties.

As of 31 December, 2008, there are 16 comprehensive income tax treaties and 14 international transportation income tax agreements which have been signed and brought into force. All tax treaties are listed below:

1. Comprehensive income tax treaties which cover all income flows: Australia, Belgium, Denmark, Gambia, Indonesia, Macedonia, Malaysia, the Netherlands, New Zealand, Senegal, Singapore, South Africa, Swaziland, Sweden , Vietnam and UK

2. International transportation income tax agreements: Canada, the European Union, Germany, Israel, Japan, Korea, Luxembourg, Macau, the Netherlands (Shipping, Air Transport), Norway, Sweden, Thailand and the United States.

The ROC's withholding tax rate on dividends, interest, and royalties payable to a non-resident is 20%, but the dividend withholding rate is 30% for non-resident individuals and 25% for non-resident enterprises for investments not approved under the Statute for Investment by Overseas Chinese or the Statute for Investment by Foreign Nationals. However, with respect to dividends, interest, and royalties, reduced withholding tax rates ranging from 5-15% are provided for by treaty.