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Taxation Administration,Ministry of Finance,R.O.C.Law Source Retrieving System of Taxation Laws and Regulations


Tax Related Laws & Regulations

Tax Act:
Regulations Governing Application of Agreements for the Avoidance of Double Tax
Article 8
In the case where an enterprise of the other Contracting State carries on a building site, construction, installation, or assembly project in the territory of the ROC for a period of time exceeding a certain duration of time and is deemed to have a PE in the ROC in accordance with the provisions for PE under the DTA, the duration of time shall be determined by the calculation of the total period of time from the date on which the contractor begins his or her work on building, construction, installation or assembly, including any preparatory work, until the work is completed or the project is permanently abandoned. Seasonal or other temporary interruptions shall be included in determining the duration of time. If an enterprise which has undertaken the performance of a comprehensive project subcontracts parts of such a project to other enterprises, the period spent by a subcontractor working on such a project shall be included in determining the duration of time.
The aforementioned term “building site, construction, installation, or assembly project” includes the work of building, renovation, excavating, dredging, and laying of pipe-lines for a building, road, bridge, canal, etc. project.

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