The Double Taxation Relief (Taxes on Income)(Taiwan) Order 2002

Article 24 Non-discrimination

(1) Citizens or nationals of a territory shall not be subjected in the other territory to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which citizens or nationals of that other territory in the same circumstances, in particular with respect to residence, are or may be subjected.

(2) A legal person, partnership or association deriving its status as such from the law in one of the territories shall not be subjected in the other territory to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which a legal person, partnership or association deriving its status as such from the law in force in that other territory in the same circumstances, in particular with respect to residence, is or may be subjected.

(3) The taxation on a permanent establishment which an enterprise of a territory has in the other territory shall not be less favourably levied in that other territory than the taxation levied on enterprises of that other territory carrying on the same activities.

(4) Except where the provisions of paragraph (1) of Article 9, paragraphs (5) or (7) of Article 11, paragraph (6) or (7) of Article 12, or paragraph (4) of Article 21 of this Agreement apply, interest, royalties and other disbursements paid by an enterprise of a territory to a resident of the other territory shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned territory.

(5) Enterprises of a territory, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other territory, shall not be subjected in the first-mentioned territory to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned territory are or may be subjected.

(6) Nothing contained in this Article shall be construed as obliging either territory to grant to individuals not resident in that territory any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident.

(7) The provisions of this Article shall apply to the taxes which are the subject of this Agreement.