The resident of the ROC, in applying for tax sparing under the provisions for elimination of double taxation under the DTA, shall provide the certificate issued by the tax authority of the other Contracting State, which shall record the laws applied, the amount of income, and the amount of the tax reduction or exemption, etc.
The tax sparing referred to in the preceding paragraph shall not include the foreign tax credits granted by the DTA between the other Contracting State and a third party.