When the tax collection authority or the Taxation Administration of the Ministry of Finance considers that the information acquired under laws as is foreseeably relevant for carrying out audit in association with taxes specified in subparagraph 2 of Article 4 by the other Contracting Party, the tax collection authority or the Taxation Administration of the Ministry of Finance may draft a letter for the provision of information in English and then submit it together with the relevant data to the competent authority of the ROC. Before drafting the above-mentioned letter, the tax collection authority or the Taxation Administration of the Ministry of Finance shall also verify that such provision of information meets the requirements prescribed in Article 4 and does not fall under one of the situations prescribed in Article 5 or subparagraph 1 or 2 of Article 6.
Information is considered as being foreseeably relevant for carrying out audit by the other Contracting Party referred to in the preceding paragraph if:
1. There may be a significant loss of tax in the other Contracting Party.
2. A person liable to tax obtains a reduction in or an exemption from tax in the ROC which could give rise to an increase tax or to liability to tax in the other Contracting Party.
3. Business dealings between a person liable to tax in the ROC and a person liable to tax in the other Contracting Party may result in loss of tax in either or both Contracting Parties.
4. A saving of tax may result from artificial transfers of profits within groups of enterprises.
5. Information, which is obtained due to the information provided by the other Contracting Party, may be relevant in assessing liability to tax in the other Contracting Party.
6. Other situations suggest that information as being foreseeably relevant for carrying out audit in association with taxes specified in subparagraph 2 of Article 4 by the other Contracting Party.
The following shall be stated in the letter for the provision of information in English specified in paragraph 1:
1. The legal basis upon which the provision of information is based.
2. Situations and their reasons concerning the information specified in the preceding paragraph as being foreseeably relevant for carrying out audit by the other Contracting Party.
3. The content of the information provided. If necessary, identify and provide relevant information with respect to the agency, institution, enterprise, organization, or individual from which the information was obtained.
4. Reasons where the other Contracting Party should avoid notifying the agency, institution, enterprise, organization, or individual to whom the provided information is related.
5. Other relevant information which may be helpful for carrying out tax audit by the other Contracting Party.

The competent authority of the ROC, having received the data under the provision of the preceding article and verified that such data meet the following requirements, shall draft a competent authority letter in English and then provide it together with the relevant data to the competent authority of the other Contracting Party; if the following requirements are not satisfied, the competent authority of the ROC shall return it to the sending authority for further investigation or supplementary explanation.
1. The information to be provided meets the requirements prescribed in Article 4 and does not fall under one of the situations prescribed in Article 5 or subparagraphs 1 and 2 of Article 6.
2. The letter for the provision of information in English is drafted in accordance with paragraph 3 of the preceding article, and relevant data are submitted.

When the competent authority of the ROC provides information to the competent authority of the other Contracting Party under a spontaneous exchange, the procedures prescribed in Article 15 concerning requirement of verification and production of documents shall be accorded mutatis mutandis. In such a case, the competent authority of the ROC shall draft the competent authority letter in English and then provide it together with the relevant data to the competent authority of the other Contracting Party.

The competent authority of the ROC shall forward the information provided by the competent authority of the other Contracting Party under a spontaneous exchange to the tax collection authority or the Taxation Administration of the Ministry of Finance to use such information.