When an investigator appointed by the tax collection authority concerned or the Taxation Administration of the Ministry of Finance, having investigated or audited a case in accordance with these Regulations, believes that there is a need to conduct a mutual agreement or consultation of the case with the other Contracting State, and recognizes that such mutual agreement or consultation with the competent authority of the other Contracting State may be allowed in accordance with the provisions of the applicable DTA, the investigator shall make a request to the competent authority of the ROC and state therein in both Chinese and English languages the reasons, relevant facts, and circumstances for conducting such a mutual agreement or consultation. The competent authority of the ROC, after receiving the above-mentioned request and agreeing the need stated therein, shall conduct a mutual agreement or consultation of that case with the competent authority of the other Contracting State.

Pursuant to the provisions in association with the term mutual agreement procedure under a DTA, where a person as specified under that DTA is eligible to present a mutual agreement procedure request for addressing the actions of one or both of the Contracting States resulting for that person in taxation not in accordance with the provisions of such DTA, the procedure for that person to present the request shall be prescribed by the Ministry of Finance. Matters with respect to the competent authority of the ROC accepting the aforesaid request and accordingly conducting mutual agreement procedure with the competent authority of the other Contracting State, or accepting the mutual agreement procedure request made by the competent authority of the other Contracting State in accordance with an applicable DTA shall also be prescribed by the Ministry of Finance.

After issuing a Certificate of Residence according to Article 38, the tax collection authority shall create a file for the relevant income data of the other Contracting State provided by the applicant. At the end of the year, all of these files created by such tax collection authority shall be delivered in bulk to the Fiscal Information Agency, Ministry of Finance for data matching.
For each case that has been approved under Articles 23 to 27, a file shall be made by the relevant tax collection authority, and be delivered in bulk to the Fiscal Information Agency, Ministry of Finance at the end of the year for data matching.

Where an investigator appointed by the tax collection authority concerned or the Taxation Administration of the Ministry of Finance finds that there is a need to verify or acquire relevant information for the purpose to carry out an investigation or audit, the investigator may make a request to the competent authority of the ROC for acquiring assistance in verifying or providing such relevant information from the competent authority of the other Contracting State, in accordance with the provisions in association with the term exchange of information under a DTA, the stipulations of the Regulations Governing the Exchange of Tax Information Concerning Agreements on Tax Matters, and other relevant laws and regulations.
When the competent authority of the other Contracting State requests information concerning property, income, business, and tax payment of the taxpayers in accordance with the provisions of the exchange of information article under a DTA, such request shall be handled by the competent authority of the ROC in accordance with the provisions of the exchange of information article under the aforementioned DTA, the stipulations of the Regulations Governing the Exchange of Tax Information Concerning Agreements on Tax Matters, and other relevant laws and regulations.