Depending on the nature of the relationship, the agreement would come into play. If it was a subsidiary corporation operating in Taiwan, then the agreement would come into play with respect to the transfer pricing of transactions between them, because the treaty provides that things must be priced at arm's length. That would come into play in determining the relative profits for any transactions between them. It would also come into play with regard to any payments between the two of them, like interest, royalties, or dividends, because one of the other advantages of the treaty is that it does generally reduce domestic withholding tax rates. The treaty would come into play in respect of those payments as well.
