On 23 June 2014, the income tax treaty between Taiwan and Kiribati entered into force. The Treaty was signed 13 May 2014, and is the first of its kind between the two countries.
The treaty covers Taiwan profit-seeking enterprise income tax, individual consolidated income tax and income basic tax. It covers Kiribati income tax.
The treaty includes provisions that a permanent establishment will be deemed constituted when an enterprise of one Contracting State furnishes services in the other State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months in any 12 month period.
Both Countries apply the credit method for the elimination of double taxation.
The treaty includes a limitation on benefits provision whereby the benefits of the treaty will not apply if the main purpose or one of the main purposes of a resident or a connected person is to take advantage of the treaty.
The treaty will apply from 1 January 2015.
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