Have agreed as follows:

Article 1
Persons Covered
This Agreement shall apply to persons who are residents of one
or both of the territories.

Article 2
Taxes Covered
1. The existing taxes to which the Agreement shall apply are:
a) in the territory in which the taxation laws administered by
the Ministry of Finance of the Slovak Republic are applied:
(i) the tax on income of individuals;
(ii) the tax on income of legal persons;
b) in the territory in which the taxation laws administered by
the Ministry of Finance of the Republic of China (Taiwan)
are applied:
(i) the profit-seeking enterprise income tax;
(ii) the individual consolidated income tax;
(iii) the income basic tax.
2. The Agreement shall apply also to any identical or
substantially similar taxes that are imposed after the date
of signature of the Agreement in addition to, or in place of,
the existing taxes. The competent authorities of the
territories shall notify each other of any significant
changes that have been made in taxation laws in force of each
of the respective territories.

Article 3
General Definitions
1. For the purposes of this Agreement, unless the context
otherwise requires:
a) the term "territory", means the territory referred to in
paragraph 1a) or 1b) of Article 2, as the context requires;
b) the term "person" includes an individual, a company and any
other body of persons;
c) the term "company" means any body corporate or any entity
which is treated as a body corporate for tax purposes;
d) the terms "enterprise of a territory" and "enterprise of
the other territory" mean respectively an enterprise
carried on by a resident of a territory and an enterprise
carried on by a resident of the other territory; e) the
term "international traffic" means any transport by a ship
or aircraft operated by an enterprise of a territory,
except when the ship or aircraft is operated solely between
places in the other territory;
f) the term "competent authority" means:
(i) in the case of the territory in which the taxation laws
administered by the Ministry of Finance of the Slovak
Republic are applied, the Ministry of Finance of the
Slovak Republic or its authorized representative, and
(ii) in the case of the territory in which the taxation laws
administered by the Ministry of Finance of the Republic
of China (Taiwan) are applied, the Minister of Finance
of the Republic of China (Taiwan) or its authorized
representative.
2. As regards the application of the Agreement at any time by a
territory, any term not defined therein shall, unless the
context otherwise requires, have the meaning that it has at
that time under the law in force of that territory for the
purposes of the taxes to which the Agreement applies, any
meaning under the tax laws in force of that territory
prevailing over a meaning given to the term under other laws
in force of that territory.

Article 4
Resident of a Territory
1. For the purposes of this Agreement, the term “resident of a
territory” means any person who, under the laws in force of
that territory, is liable to tax therein by reason of his
domicile, residence, place of management, place of
incorporation or any other criterion of a similar nature, and
also includes any authority administering the territory and
any subdivision or local authority thereof.
2. A person is not a resident of a territory for the purposes of
this Agreement if that person is liable to tax in that
territory in respect only of income from sources in that
territory, provided that this paragraph shall not apply to
individuals who are residents of the territory referred to in
paragraph 1b) of Article 2, as long as under its Income Tax
Act resident individuals are taxed only in respect of income
from sources in that territory.
3. Where by reason of the provisions of paragraphs 1 and 2 an
individual is a resident of both territories, then his status
shall be determined as follows:
a) he shall be deemed to be a resident only of the territory
in which he has a permanent home available to him; if he
has a permanent home available to him in both territories,
he shall be deemed to be a resident only of the territory
with which his personal and economic relations are closer
(centre of vital interests);
b) if the territory in which he has his centre of vital
interests cannot be determined, or if he has not a
permanent home available to him in either territory, he
shall be deemed to be a resident only of the territory in
which he has an habitual abode;
c) if he has an habitual abode in both territories or in
neither of them, he shall be deemed to be a resident only
of the territory of which he is a national under the laws
in force in that territory;
d) if he is a national as referred to under subparagraph c) of
both territories or of neither of them, the competent
authorities shall endeavour to settle the question by
mutual agreement.
4. Where by reason of the provisions of paragraphs 1 and 2 a
person other than an individual is a resident of both
territories, the competent authorities of the territories
shall settle the question by mutual agreement.

Article 5
Permanent Establishment
1. For the purposes of this Agreement, the term "permanent
establishment" means a fixed place of business through which
the business of an enterprise is wholly or partly carried on.
2. The term "permanent establishment" includes especially:
a) a place of management;
b) a branch;
c) an office;
d) a factory;
e) a workshop, and
f) a mine, an oil or gas well, a quarry or any other place of
extraction of natural resources.
3. A building site or construction or installation project
constitutes a permanent establishment only if it lasts more
than 9 months.
4. Notwithstanding the preceding provisions of this Article, the
term "permanent establishment" shall be deemed not to
include:
a) the use of facilities solely for the purpose of storage,
display or delivery of goods or merchandise belonging to
the enterprise;
b) the maintenance of a stock of goods or merchandise
belonging to the enterprise solely for the purpose of
storage, display or delivery;
c) the maintenance of a stock of goods or merchandise
belonging to the enterprise solely for the purpose of
processing by another enterprise;
d) the maintenance of a fixed place of business solely for the
purpose of purchasing goods or merchandise or of collecting
information, for the enterprise;
e) the maintenance of a fixed place of business solely for the
purpose of carrying on, for the enterprise, any other
activity of a preparatory or auxiliary character;
f) the maintenance of a fixed place of business solely for any
combination of activities mentioned in subparagraphs a) to
e), provided that the overall activity of the fixed place
of business resulting from this combination is of a
preparatory or auxiliary character.
5. Notwithstanding the provisions of paragraphs 1 and 2, where a
person - other than an agent of an independent status to whom
paragraph 6 applies - is acting on behalf of an enterprise
and has, and habitually exercises, in a territory an
authority to conclude contracts in the name of the
enterprise, that enterprise shall be deemed to have a
permanent establishment in that territory in respect of any
activities which that person undertakes for the enterprise,
unless the activities of such person are limited to those
mentioned in paragraph 4 which, if exercised through a fixed
place of business, would not make this fixed place of
business a permanent establishment under the provisions of
that paragraph.
6. An enterprise shall not be deemed to have a permanent
establishment in a territory merely because it carries on
business in that territory through a broker, general
commission agent or any other agent of an independent status,
provided that such persons are acting in the ordinary course
of their business.
7. The fact that a company which is a resident of a territory
controls or is controlled by a company which is a resident of
the other territory, or which carries on business in that
other territory (whether through a permanent establishment or
otherwise), shall not of itself constitute either company a
permanent establishment of the other.

Article 6
Income from Immovable Property
1. Income derived by a resident of a territory from immovable
property (including income from agriculture or forestry)
situated in the other territory may be taxed in that other
territory.
2. The term "immovable property" shall have the meaning which it
has under the law of the territory in which the property in
question is situated. The term shall in any case include
property accessory to immovable property, livestock and
equipment used in agriculture and forestry, rights to which
the provisions of general law in force of the territory
respecting landed property apply, usufruct of immovable
property and rights to variable or fixed payments as
consideration for the working of, or the right to work,
mineral deposits, sources and other natural resources; ships,
boats and aircraft shall not be regarded as immovable
property.
3. The provisions of paragraph 1 shall apply to income derived
from the direct use, letting, or use in any other form of
immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to the
income from immovable property of an enterprise and to income
from immovable property used for the performance of
independent personal services.

Article 7
Business Profits
1. The profits of an enterprise of a territory shall be taxable
only in that territory unless the enterprise carries on
business in the other territory through a permanent
establishment situated therein. If the enterprise carries on
business as aforesaid, the profits of the enterprise may be
taxed in the other territory but only so much of them as is
attributable to that permanent establishment.
2. Subject to the provisions of paragraph 3, where an enterprise
of a territory carries on business in the other territory
through a permanent establishment situated therein, there
shall in each territory be attributed to that permanent
establishment the profits which it might be expected to make
if it were a distinct and separate enterprise engaged in the
same or similar activities under the same or similar
conditions and dealing wholly independently with the
enterprise of which it is a permanent establishment.
3. In determining the profits of a permanent establishment,
there shall be allowed as deductions expenses which are
incurred for the purposes of the permanent establishment
including executive and general administrative expenses so
incurred, whether in the territory in which the permanent
establishment is situated or elsewhere.
4. No profits shall be attributed to a permanent establishment
by reason of the mere purchase by that permanent
establishment of goods or merchandise for the enterprise.
5. For the purposes of the preceding paragraphs, the profits to
be attributed to the permanent establishment shall be
determined by the same method, year by year, unless there is
good and sufficient reason to the contrary.
6. Where profits include items of income which are dealt with
separately in other Articles of this Agreement, then the
provisions of those Articles shall not be affected by the
provisions of this Article.

Article 8
Shipping and Air Transport
1. Profits of an enterprise of a territory from the operation of
ships or aircraft in international traffic shall be taxable
only in that territory.
2. For the purposes of this Article, profits from the operation
of ships or aircraft in international traffic include:
a) profits from the rental on a full (time or voyage) basis or
a bareboat basis of ships or aircraft, and
b) profits from the use, maintenance or rental of containers
(including trailers and related equipment for the transport
of containers) used for the transport of goods or
merchandise, where such rental or such use, maintenance or
rental, as the case may be, is incidental to the operation
of ships or aircraft in international traffic.
3. The provisions of paragraph 1 shall also apply to profits
from the participation in a pool, a joint business or an
international operating agency, but only to so much of the
profits so derived as is attributable to the participant in
proportion to its share in the joint operation.

Article 9
Associated Enterprises
1. Where
a) an enterprise of a territory participates directly or
indirectly in the management, control or capital of an
enterprise of the other territory, or
b) the same persons participate directly or indirectly in the
management, control or capital of an enterprise of a
territory and an enterprise of the other territory,
and in either case conditions are made or imposed between the
two enterprises in their commercial or financial relations
which differ from those which would be made between
independent enterprises, then any profits which would, but
for those conditions, have accrued to one of the enterprises,
but, by reason of those conditions, have not so accrued, may
be included in the profits of that enterprise and taxed
accordingly.
2. Where an authority administering the territory includes in
the profits of an enterprise of that territory - and taxes
accordingly - profits on which an enterprise of the other
territory has been charged to tax in that other territory and
the profits so included are profits which would have accrued
to the enterprise of the first-mentioned territory if the
conditions made between the two enterprises had been those
which would have been made between independent enterprises,
then that the authority administering that other territory
shall make an appropriate adjustment to the amount of the tax
charged therein on those profits if the authority
administering that other territory considers the adjustment
justified. In determining such adjustment, due regard shall
be had to the other provisions of this Agreement and the
competent authorities of territories shall if necessary
consult each other.

Article 10
Dividends
1. Dividends paid by a company which is a resident of a
territory to a resident of the other territory may be taxed
in that other territory.
2. However, such dividends may also be taxed in the territory of
which the company paying the dividends is a resident and
according to the laws of that territory, but if the
beneficial owner of the dividends is a resident of the other
territory, the tax so charged shall not exceed 10 per cent of
the gross amount of the dividends.
This paragraph shall not affect the taxation of the company
in respect of the profits out of which the dividends are paid.
3. The term "dividends" as used in this Article means income
from shares, "jouissance" shares or "jouissance" rights,
mining shares, founders’ shares or other rights, not being
debt-claims, participating in profits, as well as income from
other corporate rights which is subjected to the same
taxation treatment as income from shares by the laws in force
of the territory of which the company making the distribution
is a resident.
4. The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the dividends, being a resident of a
territory, carries on business in the other territory of
which the company paying the dividends is a resident, through
a permanent establishment situated therein, or performs in
that other territory independent personal services from a
fixed base situated therein, and the holding in respect of
which the dividends are paid is effectively connected with
such permanent establishment or fixed base. In such case the
provisions of Article 7 or Article 14, as the case may be,
shall apply.
5. Where a company which is a resident of a territory derives
profits or income from the other territory, that other
territory may not impose any tax on the dividends paid by the
company, except insofar as such dividends are paid to a
resident of that other territory or insofar as the holding in
respect of which the dividends are paid is effectively
connected with a permanent establishment or a fixed base
situated in that other territory, nor subject the company's
undistributed profits to a tax on the company's undistributed
profits, even if the dividends paid or the undistributed
profits consist wholly or partly of profits or income arising
in such other territory.

Article 11
Interest
1. Interest arising in a territory and paid to a resident of the
other territory may be taxed in that other territory.
2. However, such interest may also be taxed in the territory in
which it arises and according to the laws in force of that
territory, but if the beneficial owner of the interest is a
resident of the other territory, the tax so charged shall not
exceed 10 per cent of the gross amount of the interest.
3. Notwithstanding the provisions of paragraphs 1 and 2,
interest arising in a territory shall be exempt from tax in
that territory if it is paid:
a) to the authority administering the other territory, a
subdivision or a local authority or the Central Bank
thereof in relation to any loan, debt-claim or credit
granted by any such bodies;
b) in respect of a loan granted, guaranteed or insured or a
credit extended, guaranteed or insured by an approved
instrumentality of the other territory which aims at
promoting export.
4. The term "interest" as used in this Article means income from
debt-claims of every kind, whether or not secured by mortgage
and whether or not carrying a right to participate in the
debtor’s profits, and in particular, income from government
securities and income from bonds or debentures, including
premiums and prizes attaching to such securities, bonds or
debentures. However, the term "interest" shall not include
for the purpose of this Article income dealt with in Article
10, penalty charges for late payment and interest on
commercial debt-claims resulting from deferred payments for
goods, merchandise or services supplied by an enterprise.
5. The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the interest, being a resident of a
territory, carries on business in the other territory in
which the interest arises, through a permanent establishment
situated therein, or performs in that other territory
independent personal services from a fixed base situated
therein, and the debt-claim in respect of which the interest
is paid is effectively connected with such permanent
establishment or fixed base. In such case the provisions of
Article 7 or Article 14, as the case may be, shall apply.
6. Interest shall be deemed to arise in a territory when the
payer is a resident of that territory. Where, however, the
person paying the interest, whether he is a resident of a
territory or not, has in a territory a permanent
establishment or a fixed base in connection with which the
indebtedness on which the interest is paid was incurred, and
such interest is borne by such permanent establishment or
fixed base, then such interest shall be deemed to arise in
the territory in which the permanent establishment or fixed
base is situated.
7. Where, by reason of a special relationship between the payer
and the beneficial owner or between both of them and some
other person, the amount of the interest, having regard to
the debtclaim for which it is paid, exceeds the amount which
would have been agreed upon by the payer and the beneficial
owner in the absence of such relationship, the provisions of
this Article shall apply only to the last-mentioned amount.
In such case, the excess part of the payments shall remain
taxable according to the laws in force of each territory, due
regard being had to the other provisions of this Agreement.

Article 12
Royalties
1. Royalties arising in a territory and paid to a resident of
the other territory may be taxed in that other territory.
2. However, such royalties may also be taxed in the territory in
which they arise and according to the laws in force of that
territory, but if the beneficial owner of the royalties is a
resident of the other territory, the tax so charged shall not
exceed:
a) 5 per cent of the gross amount of the royalties paid as a
consideration for the use of, or the right to use,
industrial, commercial, or scientific equipment, and
b) 10 per cent of the gross amount of the royalties in all
other cases.
3. The term “royalties” as used in this Article means payments
of any kind received as a consideration for the use of, or
the right to use, any copyright of literary, artistic or
scientific work including cinematograph films, any patent,
trademark, design or model, plan, secret formula or process,
or for the use of, or the right to use, industrial,
commercial, or scientific equipment or for information
concerning industrial, commercial or scientific experience.
4. The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the royalties, being a resident of a
territory, carries on business in the other territory in
which the royalties arise, through a permanent establishment
situated therein, or performs in that other territory
independent personal services from a fixed base situated
therein, and the right or property in respect of which the
royalties are paid is effectively connected with such
permanent establishment or fixed base. In such case the
provisions of Article 7 or Article 14 shall apply.
5. Royalties shall be deemed to arise in a territory when the
payer is a resident of that territory. Where, however, the
person paying the royalties, whether he is a resident of a
territory or not, has in a territory a permanent
establishment or a fixed base in connection with which the
liability to pay the royalties was incurred, and such
royalties are borne by such permanent establishment or fixed
base, then such royalties shall be deemed to arise in the
territory in which the permanent establishment or fixed base
is situated.
6. Where, by reason of a special relationship between the payer
and the beneficial owner or between both of them and some
other person, the amount of the royalties, having regard to
the use, right or information for which they are paid,
exceeds the amount which would have been agreed upon by the
payer and the beneficial owner in the absence of such
relationship, the provisions of this Article shall apply only
to the last-mentioned amount. In such case, the excess part
of the payments shall remain taxable according to the laws in
force of each territory, due regard being had to the other
provisions of this Agreement.

Article 13
Capital Gains
1. Gains derived by a resident of a territory from the
alienation of immovable property referred to in Article 6 and
situated in the other territory may be taxed in that other
territory.
2. Gains from the alienation of movable property forming part of
the business property of a permanent establishment which an
enterprise of a territory has in the other territory or of
movable property pertaining to a fixed base available to a
resident of a territory in the other territory for the
purpose of performing independent personal services,
including such gains from the alienation of such a permanent
establishment (alone or with the whole enterprise) or of such
fixed base, may be taxed in that other territory.
3. Gains derived by an enterprise of a territory from the
alienation of ships or aircraft operated in international
traffic, or movable property pertaining to the operation of
such ships or aircraft, shall be taxable only in that
territory.
4. Gains derived by a resident of a territory from the
alienation of shares or other similar rights in a company
deriving more than 50% of their value directly or indirectly
from immovable property situated in the other territory may
be taxed in that other territory.
5. Gains from the alienation of any property other than that
referred in the preceding paragraphs, shall be taxable only
in the territory of which the alienator is a resident.

Article 14
Independent Personal Services
1. Income derived by a resident of a territory in respect of
professional services or other activities of an independent
character shall be taxable only in that territory except in
the following circumstances, when such income may also be
taxed in the other territory:
a) if he has a fixed base regularly available to him in the
other territory for the purpose of performing his
activities; in that case, only so much of the income as is
attributable to that fixed base may be taxed in that
territory; or
b) if his stay in the other territory is for a period or
periods amounting to or exceeding in the aggregate 183 days
in any twelve-month period commencing or ending in the
calendar year concerned; in that case, only so much of the
income as is derived from his activities performed in the
other territory may be taxed in that territory.
2. The term “professional services“ includes especially
independent scientific, literary, artistic, educational or
teaching activities as well as the independent activities of
physicians, lawyers, engineers, architects, dentists and
accountants.

Article 15
Income from Employment
1. Subject to the provisions of Articles 16, 18 and 19,
salaries, wages and other similar remuneration derived by a
resident of a territory in respect of an employment shall be
taxable only in that territory unless the employment is
exercised in the other territory. If the employment is so
exercised, such remuneration as is derived therefrom may be
taxed in that other territory.
2. Notwithstanding the provisions of paragraph 1, remuneration
derived by a resident of a territory in respect of an
employment exercised in the other territory shall be taxable
only in the firstmentioned territory if:
a) the recipient is present in the other territory for a
period or periods not exceeding in the aggregate 183 days
in any twelve month period commencing or ending in the
fiscal year concerned, and
b) the remuneration is paid by, or on behalf of, an employer
who is not a resident of the other territory, and
c) the remuneration is not borne by a permanent establishment
which the employer has in the other territory.
3. Notwithstanding the preceding provisions of this Article,
remuneration derived in respect of an employment exercised
aboard a ship or aircraft operated in international traffic,
may be taxed in the territory of which the enterprise is a
resident.

Article 16
Director’s Fees
Directors' fees and other similar payments derived by a resident
of a territory in his capacity as a member of the board of
directors or any other similar organ having supervisory
functions of a company which is a resident of the other
territory may be taxed in that other territory.

Article 17
Artistes and Sportsmen
1. Notwithstanding the provisions of Articles 14 and 15, income
derived by a resident of a territory as an entertainer, such
as a theatre, motion picture, radio or television artiste, or
a musician, or as a sportsman, from his personal activities
as such exercised in the other territory, may be taxed in
that other territory.
2. Where income in respect of personal activities exercised by
an entertainer or a sportsman in his capacity as such accrues
not to the entertainer or sportsman himself but to another
person, that income may, notwithstanding the provisions of
Articles 7, 14 and 15, be taxed in the territory in which the
activities of the entertainer or sportsman are exercised.
3. The provisions of paragraphs 1 and 2 shall not apply to
income derived from activities exercised in a territory by an
artistes or sportsmen if the visit to that territory is
wholly or mainly supported by public funds of one or both of
the authorities administering a territory or any subdivision
or local authority thereof. In such case, the income is
taxable only in the territory of which the artiste or the
sportsman is a resident.

Article 18
Pensions and Annuities
1. Pensions and other similar remuneration paid to a resident of
a territory in consideration of past employment, shall be
taxable only in the territory in which they arise. This
provision shall also apply to annuities and to pensions and
other similar remuneration paid under social security
legislation in force in that territory or under a public
scheme organized by that territory in order to supplement the
benefits of that social security legislation.
2. The term “annuity” means a stated sum payable periodically
at stated times during life or during a specified or
ascertainable period of time under an obligation to make the
payments in return for adequate and full consideration in
money or money’s worth.

Article 19
Government Services
1.
a) Salaries, wages and other similar remuneration, other than
a pension or annuity, paid by an authority administering a
territory or a subdivision thereof or a local authority of
that territory to an individual in respect of services to
such authorities shall be taxable only in that territory.
b) However, such salaries, wages and other similar
remuneration shall be taxable only in the other territory
if the services are rendered in that territory and the
individual is a resident of that territory who:
(i) is a national of a territory under the laws in force in
that territory; or
(ii) did not become a resident of that territory solely for
the purpose of rendering the services.
2. The provisions of Articles15, 16, 17 and 18 shall apply to
salaries, wages and other similar remuneration, and to
pensions or annuities, in respect of services rendered in
connection with a business carried on by an authority
administering the territory or a subdivision or a local
authority thereof.

Article 20
Students
Payments which a student or business apprentice who is or was
immediately before visiting a territory a resident of the other
territory and who is present in the first-mentioned territory
solely for the purpose of his education or training receives for
the purpose of his maintenance, education or training shall not
be taxed in that territory, provided that such payments arise
from sources outside that territory.

Article 21
Other Income
1. Items of income of a resident of a territory, wherever
arising, not dealt with in the foregoing Articles of this
Agreement shall be taxable only in that territory.
2. The provisions of paragraph 1 shall not apply to income,
other than income from immovable property as defined in
paragraph 2 of Article 6, if the recipient of such income,
being a resident of a territory, carries on business in the
other territory through a permanent establishment situated
therein, or performs in that other territory independent
personal services from a fixed base situated therein, and the
right or property in respect of which the income is paid is
effectively connected with such permanent establishment or
fixed base. In such case the provisions of Article 7 or 14,
as the case may be, shall apply.
3. Notwithstanding the provisions of paragraphs 1 and 2 of this
Article, items of income of a resident of a territory not
dealt with in the foregoing Articles of this Agreement and
arising in the other territory may also be taxed in that
other territory.

Article 22
Elimination of Double Taxation
1. Subject to the provision of the laws in force of the
territory referred to in paragraph 1a) of Article 2, double
taxation shall be eliminated as follows:
a) when imposing taxes on its residents, the competent
authority of the territory referred to in paragraph 1a) of
Article 2 may include in the tax base upon which such taxes
are imposed the items of income which according to the
provisions of this Agreement may also be taxed in the
territory referred to in paragraph 1b) of Article 2, but
shall allow as a deduction from the amount of tax computed
on such a base an amount equal to the tax paid in the
territory referred to in paragraph 1b) of Article 2;
b) such deduction shall not, however, exceed that part of the
tax payable in the territory referred to in paragraph 1a)
of Article 2, as computed before the deduction is given,
which is appropriate to the income that may be taxed in the
territory referred to in paragraph 1b) of Article 2 in
accordance with the provisions of this Agreement.
2. Subject to the provision of the laws in force of the
territory referred to in paragraph 1b) of Article 2, double
taxation shall be eliminated as follows:
Where a resident of the territory referred to in paragraph 1b)
of Article 2 derives income from the other territory, the amount
of tax on that income paid in the other territory (but
excluding, in the case of a dividend, tax paid in respect of the
profits out of which the dividend is paid) and in accordance
with the provisions of this Agreement, shall be credited against
the tax levied in the firstmentioned territory imposed on that
resident. The amount of credit, however, shall not exceed the
amount of the tax in the firstmentioned territory on that income
computed in accordance with its taxation laws and regulations.

Article 23
Non-Discrimination
1. Nationals of a territory under the laws in force in that
territory shall not be subjected in the other territory to
any taxation or any requirements connected therewith which is
other or more burdensome than the taxation and connected
requirements, to which nationals of that other territory in
the same circumstances, in particular with respect to
residence, are or may be subjected. This provision shall,
notwithstanding the provisions of Article 1, also apply to
persons who are not residents of one or both of the
territories.
2. 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. This provision shall not be construed as
obliging a territory to grant to residents of the other
territory any personal allowances, reliefs and reductions for
taxation purposes on account of civil status or family
responsibilities which it grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9,
paragraph 7 of Article 11, or paragraph 6 of Article 12
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.
4. 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 firstmentioned 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.
5. The provisions of this Article shall apply to taxes which are
the subject of this Agreement.

Article 24
Mutual Agreement Procedure
1. Where a person considers that the actions of authorities of
one or both of the territories result or will result for him
in taxation not in accordance with the provisions of this
Agreement, he may, irrespective of the remedies provided by
the domestic law in force of those territories, present his
case to the competent authority administering the territory
of which he is a resident or, if his case comes under
paragraph 1 of Article 23, to that of the territory of which
he is a national under the laws in force of that territory.
The case must be presented within three years from the first
notification of the action resulting in taxation not in
accordance with the provisions of the Agreement.
2. The competent authority shall endeavour, if the objection
appears to it to be justified and if it is not itself able to
arrive at a satisfactory solution, to resolve the case by
mutual agreement with the competent authority of the other
territory, with a view to the avoidance of taxation which is
not in accordance with the Agreement. Any agreement reached
shall be implemented notwithstanding any time limits in the
domestic law of territories.
3. The competent authorities of the territories shall endeavour
to resolve by mutual agreement any difficulties or doubts
arising as to the interpretation or application of the
Agreement. They may also consult together for the elimination
of double taxation in cases not provided for in the
Agreement.
4. The competent authorities of the territories may communicate
with each other directly for the purpose of reaching an
agreement in the sense of the preceding paragraphs.

Article 25
Exchange of Information
1. The competent authorities of the territories shall exchange
such information as is foreseeably relevant for carrying out
the provisions of this Agreement or of the domestic laws
concerning taxes of every kind and description imposed on
behalf of the territories, or of their subdivisions or local
authorities, insofar as the taxation thereunder is not
contrary to the Agreement. The exchange of information is not
restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a competent
authority of the territory shall be treated as secret in the
same manner as information obtained under the laws in force
of that territory and shall be disclosed only to persons or
authorities (including courts and administrative bodies)
concerned with the assessment or collection of, the
enforcement or prosecution in respect of, the determination
of appeals in relation to the taxes referred to in paragraph
1. Such persons or authorities shall use the information only
for such purposes. They may disclose the information in
public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be
construed so as to impose on a competent authority of a
territory the obligation:
a) to carry out administrative measures at variance with the
laws in force of the territory and administrative practice
of that or of the other territory;
b) to supply information which is not obtainable under the
laws in force of the territory or in the normal course of
the administration of that or of the other territory;
c) to supply information which would disclose any trade,
business, industrial, commercial or professional secret or
trade process, or information the disclosure of which would
be contrary to public policy (ordre public).
4. If information is requested by a competent authority of the
territory in accordance with this Article, the other
competent authority of the territory shall use its
information gathering measures to obtain the requested
information, even though that other competent authority of
the territory may not need such information for its own tax
purposes. The obligation contained in the preceding sentence
is subject to the limitations of paragraph 3 but in no case
shall such limitations be construed to permit a competent
authority of the territory to decline to supply information
solely because it has no domestic interest in such
information.

Article 26
Limitation on Benefits
1. Notwithstanding the provisions of any other Article of this
Agreement, a resident of a territory shall not receive the
benefit of any reduction in or exemption from tax provided
for in the Agreement by the other territory if the competent
authority of the other territory determines that 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.
2. The Agreement shall not prevent a territory from applying its
domestic laws on the prevention of tax evasion or tax
avoidance.

Article 27
Entry into Force
This Agreement shall be approved in accordance with the internal
legal procedures under the laws in force of both territories and
shall enter into force on the 30th day after the date of the
later written information of the competent authority confirming
that the internal legal procedures have been completed. The
provisions of this Agreement shall thereupon have effect in both
territories
a) in respect of taxes withheld at source, to income payable
on or after the first day of January of the calendar year
following the year in which this Agreement enters into
force;
b) in respect of other taxes, to such taxes as will be imposed
for any tax periods beginning on or after the first day of
January of the calendar year following the year in which
this Agreement enters into force.

Article 28
Termination
1. This Agreement shall remain in force for an indefinite period
until terminated by one of the competent authorities.
2. Either of the competent authorities may terminate this
Agreement by giving notice of termination, at least six
months before the end of any calendar year following after
the period of at least five years from the date on which this
Agreement enters into force. In such event, the Agreement
shall cease to have effect in both territories
a) in respect of taxes withheld at source, to income payable
on or after the first day of January in the calendar year
next following the year in which the notice of termination
is given;
b) in respect of other taxes, in any tax year beginning on or
after the first day of January in the calendar year next
following the year in which the notice of termination is
given.


In witness whereof, the undersigned, being duly authorised
thereto, have signed this Agreement.


Done in duplicate at ...................... this ....... day of
................. 20...., each original in the Chinese, Slovak
and English languages. In case of divergence of interpretation,
the English text shall prevail.



For For
The Ministry of Finance of the The Ministry of Finance of the
Republic of China (Taiwan) Slovak Republic



______________________________ ________________________________
Director General of the Director General of the Tax and
Taxation Agency Customs Section