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HMRC internal manual

Double Taxation Relief Manual

Taiwan: Limitation of relief

Taiwan has domestic laws giving incentives to promote foreign investment, whereby certain residents are not subject to tax or are subject to tax at a reduced on income or capital gains.

If a resident of Taiwan benefits from this domestic law they are not entitled to any reduction in or exemption from United Kingdom tax if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement (see Article 23).

The Tax Treaty Team should be consulted if it is considered relief should be limited under this provision.