The Taipei Economic and Cultural Representative Office in the
Kingdom of Saudi Arabia (TECRO) and the Council for Saudi
Chambers of Commerce and Industry (CSC) (referred hereinafter as
the Contracting Parties),

DESIRING to conclude an Agreement for the avoidance of double
taxation with respect to taxes on income and the prevention of
tax evasion; without creating opportunities for non-taxation or
reduced taxation through tax evasion or avoidance (including
through treaty – shopping arrangements aimed at obtaining
reliefs provided in this Agreement for the indirect benefit of
residents of third territory),

HAVE AGREED as follows:

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

Article 2
Taxes Covered
1. The existing taxes to which this Agreement shall apply are in
particular:
(a) in the case of the territory represented by the CSC in which
the Saudi taxation laws are applied:
(i) the Zakat;
(ii) the income tax including the natural gas investment tax,
and
(b) in the case of the territory represented by the TECRO in
which the Taiwanese taxation laws are applied:
(i) the profit-seeking enterprise income tax;
(ii) the individual consolidated income tax;
(iii) the income basic tax.
2. The provisions of this Agreement shall apply also to any
identical or substantially similar taxes that are imposed in
either territory after the date of signature of this
Agreement in addition to, or in place of, the existing taxes.
The competent authorities of both territories shall notify
each other of any significant changes that have been made in
their respective taxation laws.

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 1 (a) or 1 (b) of Article 2 of this Agreement, and
the terms “ other territory ” or “ territories ” shall
be construed as the case requires;
(b) the term “ person ” includes an individual, a company or
any other body of persons including partnership and trust;
(c) the term “ company ” means any body corporate or any
entity that 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 that has its
place of effective management in 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 represented by the CSC in
which the Saudi taxation laws are applied, the appropriate
authority responsible for taxation or its authorized
representative;
(ii) in the case of the territory represented by the TECRO in
which the Taiwanese taxation laws are applied, the
Minister of Finance or his authorized representative.
2. As regards the application of this 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 of that territory for the purposes of
the taxes to which this Agreement applies, any meaning under
the applicable tax laws of that territory prevailing over a
meaning given to the term under other laws of that territory.

Article 4
Resident
1. For the purposes of this Agreement, the term “ resident of a
territory" means any person who, under the laws of that
territory is liable to tax therein by reason of his domicile,
residence, place of incorporation, place of management or any
other criterion of a similar nature. This term, however, does
not include any person who is liable to tax in that territory
in respect only of income from sources in that territory.
2. Where by reason of the provisions of paragraph 1 of this
Article, 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 (center
of vital interests);
(b) if the territory in which he has his center 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, the competent authorities of the
territories shall settle the question by mutual agreement.
3. Where by reason of the provisions of paragraph 1 of this
Article, a person other than an individual is a resident of
both territories, then it shall be deemed to be a resident
only of the territory in which its place of effective
management is situated.

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 but is not
limited to:
(a) a place of management;
(b) a branch;
(c) an office;
(d) a factory;
(e) a workshop;
(f) a mine, a quarry or any other place of extraction of natural
resources.
3. The term “permanent establishment” also includes:
(a) a building site, a construction, assembly or installation
project, or supervisory activities, in connection therewith,
but only where such site, project or activities continue for
a period more than 6 months;
(b) the furnishing of services, including consultancy services,
by an enterprise through employees or other personnel
engaged by the enterprise for such purpose, but only where
activities of that nature continue (for the same or a
connected project) within a territory for a period or
periods aggregating more than 6 months within any 12-month
period.
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 of this
Article, where a person - other than an agent of an
independent status to whom paragraph 6 of this Article
applies - is acting in a territory on behalf of an enterprise
of the other territory, that enterprise shall be deemed to
have a permanent establishment in the first-mentioned
territory in respect of any activities which that person
undertakes for the enterprise, if such a person has and
habitually exercises in that territory an authority to
conclude contracts in the name of the enterprise, unless the
activities of such person are limited to those mentioned in
paragraph 4 of this Article 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 of a territory shall not be deemed to have a
permanent establishment in the other territory merely because
it carries on business in that other 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. This 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 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 of this Article 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 of this Article 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 of this Article,
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 the determination of the profits of a permanent
establishment, there shall be allowed as deductions expenses
which are incurred for the purposes of the business 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. Notwithstanding other provisions, the business profits
derived by an enterprise of a territory from the exportation
of merchandise to the other territory shall not be taxed in
that other territory. Where export contracts include other
activities carried on through a permanent establishment in
the other territory, profits derived from such activities may
be taxed in the other territory.
5. Nothing in this Article shall affect the operation of any law
of a territory relating to tax imposed on income derived by
non-residents from insurance activities.
6. Insofar as it has been customary in a territory to determine
the profits to be attributed to a permanent establishment on
the basis of an apportionment of the total profits of the
enterprise to its various parts, nothing in paragraph 2 of
this Article shall preclude that territory from determining
the profits to be taxed by such an apportionment as may be
customary; the method of apportionment adopted shall,
however, be such that the result shall be in accordance with
the principles contained in this Article.
7. 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.
8. 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.
9. 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 from the operation of ships or aircraft in
international traffic shall be taxable only in the territory
in which the place of effective management of the enterprise
is situated.
2. Profits from the operation of ships or aircraft in
international traffic include:
(a) profits derived from the rental on a full (time or voyage)
basis of ships or aircraft used in international transport;
(b) profits derived from the rental on a bareboat basis of ships
or aircraft used in international transport;
(c) profits derived from the use, maintenance or rental of
containers and related equipment used in international
transport;

where such rental, use or maintenance, as the case may be, is
incidental to the operation of ships or aircraft in
international traffic.

3. If the place of effective management of a shipping enterprise
is aboard a ship, then it shall be deemed to be situated in
the territory in which the home harbour of the ship is
situated, or, if there is no such home harbour, in the
territory of which the operator of the ship is a resident.
4. The provisions of paragraph 1 of this Article shall also
apply to profits from the participation in a pool, a joint
business or an international operating agency.

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 a 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 other territory
shall make an appropriate adjustment to the amount of the tax
charged therein on those profits if 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 the
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 12.5 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 of
the territory of which the company making the distribution is
a resident.
4. The provisions of paragraphs 1 and 2 of this Article 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 of this
Agreement, 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
Income from Debt-Claims
1. Income from debt-claims arising in a territory and paid to a
resident of the other territory may be taxed in that other
territory.
2. However, such income from debt-claims may also be taxed in
the territory in which it arises and according to the laws of
that territory, but if the beneficial owner of the income
from debt-claims is a resident of the other territory, the
tax so charged shall not exceed 10 per cent of the gross
amount of the income from debt-claims.
3. Notwithstanding the provisions of paragraph 2 of this
Article, income from debt-claims arising in a territory shall
be exempted from tax in that territory if it is paid:
(a) to the Central Bank of the other territory, or
(b) to any financial institution wholly owned or controlled by a
public authority of the other territory.
4. The term “ Income from Debt-Claims ” 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. Penalty charges for
late payment shall not be regarded as income from debt-claims
for the purpose of this Article.
5. The provisions of paragraphs 1 and 2 of this Article shall
not apply if the beneficial owner of the income from
debt-claims, being a resident of a territory, carries on
business in the other territory in which the income from
debt-claims 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-claims in respect of which such income
is paid is effectively connected with such permanent
establishment or fixed base. In such case, the provisions of
Article 7 or Article 14 of this Agreement, as the case may
be, shall apply.
6. Income from debt-claims shall be deemed to arise in a
territory when the payer is a resident of that territory.
Where, however, the person paying such income, 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 such income is paid was
incurred, and such income is borne by such permanent
establishment or fixed base, then such income 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 income from debt-claims,
having regard to the debt-claim 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 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 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) 4 per cent of the gross amount of such royalties which are
paid for the use of, or the right to use, industrial,
commercial, or scientific equipment, and
(b) 10 per cent of the gross amount of such royalties in all
other cases.
3. The term “ royalties ” as used in this Article means
payment 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, or films or
tapes used for radio or television broadcasting, any patent,
trade mark, 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 of this Article 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 of this Agreement, as
the case may be, 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 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 of
this Agreement 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 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
the territory in which the place of effective management of
the enterprise is situated.
4. Gains derived by a resident of a territory from the
alienation of shares of a company which is a resident of the
other territory may be taxed in that other territory if
shares owned by the alienator amount to at least 25 per cent
of the total issued shares of such company at any time during
the 7-year period immediately preceding the alienation of
such shares.
5. Gains derived from the alienation of any property other than
that referred to 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 other
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
fiscal year concerned; in that case, only so much of the
income as is derived from his activities performed in that
other territory may be taxed in that other 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
Dependent Personal Services
1. Subject to the provisions of Articles 16, 18, 19, 20 and 21
of this Agreement, 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 of this
Article, remuneration derived by a resident of a territory in
respect of an employment exercised in the other territory
shall be taxable only in the first-mentioned 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
or a fixed base 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 in which the place of effective
management of the enterprise is situated.

Article 16
Directors’ 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 of a company which is a resident of the other
territory may be taxed in that other territory.

Article 17
Artistes and Sportspersons
1. Notwithstanding the provisions of Articles 14 and 15 of this
Agreement, 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 sportsperson, 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 sportsperson in his capacity as such
accrues not to the entertainer or sportsperson himself but to
another person, that income may, notwithstanding the
provisions of Articles 7, 14 and 15 of this Agreement, be
taxed in the territory in which the activities of the
entertainer or sportsperson are exercised.
3. Income derived by a resident of a territory from activities
exercised in the other territory as envisaged in paragraphs 1
and 2 of this Article, shall be exempted from tax in that
other territory, if the visit to that other territory, is
supported wholly or mainly by public funds of one or both of
the territories, or takes place under a cultural agreement or
arrangement between both territories.

Article 18
Pensions
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 by an entity of a territory
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
Public Service
1.
(a) Salaries, wages and other similar remuneration, other than a
pension or annuity, paid by a public authority of a
territory to an individual in respect of public services
rendered to that territory 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 other territory, and the individual is
a resident of that other territory, who:
(i) is a national of that other territory, or
(ii) did not become a resident of that other territory solely
for the purpose of rendering the services.
2. The provisions of Articles 15, 16, 17 and 18 of this
Agreement 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
a public authority of a territory.

Article 20
Students
1. Payments which a student or trainee or 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.
2. Payments received by the student 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 and which
constitute remuneration in respect of services performed in
the first-mentioned territory are not taxable in that
territory, provided that:
(a) the amount shall not exceed 10,000 United States dollars
during each calendar year for a period not exceeding 6
years;
(b) the services are connected with education or training and
are necessary for maintenance purposes.

Article 21
Teachers and Researchers
1. An individual who visits a territory for the purpose of
teaching or carrying out research at a university, college or
other recognized educational institution in that territory
and who is or was immediately before visiting a territory, a
resident of the other territory, shall be exempted from
taxation in the first-mentioned territory on remuneration for
such teaching or conducting research for a period not
exceeding 2 years from the date of his first visit for that
purpose.
2. The provision of paragraph 1 of this Article shall not apply
to income from research if such research is undertaken not in
the public interest but primarily for the private benefit of
a specific person or persons.

Article 22
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 of this Article shall not apply
to income, other than income from immovable property as
defined in paragraph 2 of Article 6 of this Agreement, 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 Article 14 of this Agreement, 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 23
Methods for Elimination of Double Taxation
1. Double taxation shall be eliminated as follows:
(a) In the case of the territory referred to in paragraph 1 (a)
of Article 2:

Where a resident of that territory derives income which, in
accordance with the provisions of this Agreement, may be
taxed in the territory referred to in paragraph 1 (b) of
Article 2, the territory referred to in paragraph 1 (a) of
Article 2 shall allow as a deduction from the tax on the
income of that resident an amount equal to the tax paid in
the territory referred to in paragraph 1 (b) of Article 2.
Such deduction shall not, however, exceed that part of the
tax, as computed before the deduction is given, which is
attributable to such items of income derived from the
territory referred to in paragraph 1 (b) of Article 2.

(b) In the case of the territory referred to in paragraph 1 (b)
of Article 2:

Where a resident of that territory derives income from the
territory referred to in paragraph 1 (a) of Article 2, the
amount of tax on that income paid in the territory referred
to in paragraph 1 (a) of Article 2 (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 territory referred to in paragraph 1 (b)
of Article 2 imposed on that resident. The amount of credit,
however, shall not exceed the amount of the tax in the
territory referred to in paragraph 1(b) of Article 2 on that
income computed in accordance with its taxation laws and
regulations.

2. In the case of the territory referred to in paragraph 1 (a)
of Article 2, the methods for elimination of double taxation
will not prejudice to the provisions of the Zakat collection
regime as regards Saudi nationals.

Article 24
Mutual Agreement Procedure
1. Where a person considers that the actions 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 of
those territories, present his case to the competent
authority of either 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 this 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 this Agreement. Any agreement reached
shall be implemented notwithstanding any time limits in the
domestic law of the territories.
3. The competent authorities of both territories shall endeavour
to resolve by mutual agreement any difficulties or doubts
arising as to the interpretation or application of this
Agreement. They may also consult together for the elimination
of double taxation in cases not provided for in this
Agreement.
4. The competent authorities of the territories may communicate
with each other for the purpose of reaching an agreement in
the sense of the preceding paragraphs.
5. The competent authorities of the territories may by mutual
agreement settle the appropriate mode of application of this
Agreement and, especially, the requirements to which the
residents of a territory shall be subjected in order to
obtain, in the other territory, the tax reliefs or exemptions
provided for by this Agreement.

Article 25
Exchange of Information
1. The competent authorities of the territories shall exchange
such information as is necessary for carrying out the
provisions of this Agreement or of the domestic laws of the
territories concerning taxes covered by this Agreement
insofar as the taxation thereunder is not contrary to this
Agreement. The exchange of information is not restricted by
Articles 1 and 2 of this Agreement. Any information received
by a territory shall be treated as confidential in the same
manner as information obtained under the domestic laws 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, or the
determination of appeals in relation to, the taxes covered by
this Agreement. 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.
2. In no case shall the provisions of paragraph 1 of this
Article be construed so as to impose on a territory the
obligation:
(a) to carry out administrative measures at variance with the
laws and administrative practice of that or of the other
territory;
(b) to supply information which is not obtainable under the laws
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.
3. If information is requested by a competent authority of a
territory in accordance with this Article, the competent
authority of the other territory shall use its information
gathering measures to obtain the requested information, even
though that other competent authority may not need such
information for its own tax purposes. The obligation
contained in the preceding sentence is subject to the
limitations of paragraph 2 of this Article but in no case
shall such limitations be construed to permit a competent
authority to decline to supply information solely because it
has no domestic interest in such information.
4. In no case shall the provisions of paragraph 2 of this
Article be construed to permit a competent authority to
decline to supply information solely because the information
is held by a bank, other financial institution, nominee or
person acting in an agency or a fiduciary capacity or because
it relates to ownership interests in a person.
5. The information exchanged according to the provisions of this
Article shall be used only for tax purposes.

Article 26
Miscellaneous Provisions
1. Nothing in this Agreement shall affect the application of the
domestic provisions to prevent tax evasion and tax avoidance.
2. 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 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.

Article 27
Entry into Force
1. Each of the Contracting Parties shall notify to the other
Contracting Party in writing the completion of the procedures
required by the law of the territory it represents for the
entry into force of this Agreement. This Agreement shall
enter into force on the first day of the second month
following the month in which the latter of these
notifications was received.
2. The provisions of this Agreement shall apply:
(a) with regard to taxes withheld at source, in respect of
amounts paid or payable on or after the first day of January
next following the date upon which this Agreement enters
into force, and
(b) with regard to other taxes, in respect of taxable years
beginning on or after the first day of January next
following the date upon which this Agreement enters into
force.

Article 28
Termination
1. This Agreement shall remain in force indefinitely but either
of the Contracting Parties may terminate this Agreement by
giving to the other Contracting Party a written notice of
termination not later than 30 June of any calendar year
starting five years after the year in which this Agreement
entered into force.
2. In such event this Agreement shall cease to apply:
(a) with regard to taxes withheld at source, in respect of
amounts paid or payable after the end of the calendar year
in which such notice is given; and
(b) with regard to other taxes, in respect of taxable years
beginning after the end of the calendar year in which such
notice is given.

IN WITNESS WHEREOF the undersigned, being duly authorized
thereto, have signed this Agreement.

DONE in duplicate at Riyadh on Wednesday 17.4.1442 AH -
2.12.2020 in the Chinese, Arabic and English languages, all
texts being equally authentic. In case of divergence of
interpretation, the English text shall prevail.


For the Taipei Economic For the Council for Saudi
and Cultural Representative Chambers of Commerce and
Office in the Kingdom of Industry
Saudi Arabia

Teng, Sheng-Ping Ajlan bin Abdulaziz Al-Ajlan
Representative Chairman
___________________ ___________________


PROTOCOL
Upon signing the Agreement between the Taipei Economic and
Cultural Representative Office in the Kingdom of Saudi Arabia
and the Council for Saudi Chambers of Commerce and Industry for
the Avoidance of Double Taxation with respect to Taxes on Income
and the Prevention of Tax Evasion the undersigned have agreed
that the following provisions shall form an integral part of the
Agreement:
1. With reference to Paragraph 1 of Article 4 of the Agreement:
It is understood that the term "resident of a territory"
includes:
(a) any individual who is liable to tax in the territory
referred to in paragraph 1 (b) of Article 2 in respect only
of income from sources in that territory as long as such
individual is a resident in accordance with the taxation law
of that territory and is taxed only in respect of income
from sources in that territory;
(b) any legal person organized under the laws of a territory and
that is not liable to tax or is exempted from tax in that
territory and is established and maintained in that
territory either:
(i) exclusively for a religious, charitable, educational,
scientific, or other similar purpose, or
(ii) to provide pensions or other similar benefits to
employees pursuant to a plan.
2. With reference to Article 7 of the Agreement:
The term “ business profits ” includes, but is not limited
to income derived from manufacturing, mercantile, banking,
insurance, from the operation of inland transportation, the
furnishing of services and the rental of tangible personal
movable property. Such a term does not include the
performance of personal services by an individual either as
an employee or in an independent capacity.
3. With reference to Paragraph 3 of Article 7 of the Agreement:
In the case of the territory referred to in paragraph 1 (a)
of Article 2, no such deduction shall be allowed in respect
of amounts, if any, paid (otherwise than towards
reimbursement of actual expenses) by the permanent
establishment to the head office of the enterprise or any of
its other offices, by way of royalties, fees or other similar
payments in return for the use of patents or other rights, or
by way of commission, for specific services performed or for
management, or, except in the case of a banking enterprise,
by way of income from debt-claims with regard to moneys lent
to the permanent establishment. Likewise, no account shall be
taken, in the determination of the profits of a permanent
establishment, for amounts charged (otherwise than towards
reimbursement of actual expenses), by the permanent
establishment to the head office of the enterprise or any of
its other offices, by way of royalties, fees or other similar
payments in return for the use of patents or other rights, or
by way of commission for specific services performed or for
management, or, except in the case of a banking enterprise,
by way of income from debt-claims with regard to moneys lent
to the head office of the enterprise or any of its other
offices.
4. In the case in which the territory referred to in paragraph 1
(a) of Article 2 introduces an income tax applicable to its
resident nationals, or the existing tax will be modified
accordingly, the two Contracting Parties shall enter into
negotiations in order to introduce in the Agreement an
article on non-discrimination.

IN WITNESS WHEREOF the undersigned, being duly authorized
thereto, have signed this Protocol.

DONE in duplicate at Riyadh on Wednesday 17.4.1442 AH -
2.12.2020 in the Chinese, Arabic and English languages, all
texts being equally authentic. In case of divergence of
interpretation, the English text shall prevail.


For the Taipei Economic For the Council for
and Cultural Representative Saudi Chambers of Commerce
Office in the Kingdom and Industry
of Saudi Arabia

Teng, Sheng-Ping Ajlan bin Abdulaziz Al-Ajlan
Representative Chairman
___________________ ___________________