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

As of 25 December, 2012, there are 25 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：
　(1)Asia: India, Indonesia, Israel, Malaysia, Singapore, Thailand, Vietnam.
　(2)Oceania: Australia, New Zealand.
　(3)Europe: Belgium, Denmark, France,Germany, Hungary, Macedonia, the Netherlands
　　　　　　Slovakia, Sweden,Switzerland,UK.
　(4)Africa: Gambia, Senegal, South Africa, Swaziland
　(5)America:Paraguay

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 withholding rate is 15% for interest on bonds, short-term commercial papers, securitized products, interest derived from the RP/RS transactions. In addition, reduced withholding tax rates ranging from 5-15% are provided for by treaty with respect to dividends, interest, and royalties.

To improve the effectiveness of tax administration with regard to the double taxation agreements, the MOF issued the Regulations on 7 January 2010, No. 09904504820. The Regulations provide certainty and clearer guidance for application of double taxation agreements.

For more information on application of Double Taxation Agreements, please consult the tax administration authority-in-charge.