What a treaty does would depend on the nature of what the company is doing in Taiwan, but if a Canadian company is operating in Taiwan and it hits the threshold of what is called the permanent establishment, which is set out in article 5, then the treaty sets out that yes, Taiwan would have a certain taxing right in respect of income that is sourced in Taiwan, so there would still be obligations in Taiwan and if, under the treaty, Taiwan has a certain obligation, then it would be Canada that would give a tax credit. However, if the activity in which it engages in Taiwan does not meet the threshold of a PE, permanent establishment, then it would have no obligations in Taiwan.
