working notes- about tax treaty

there're usually two parts of tax treaty
1. upper limit tax rate
items that applicable for upper limit tax rate won't follow domestic tax rate.
it's usually regulated withholding rate.
therefore, interest, royalty, technical services withholding rate is not the same with domestic tax law, instead it directly applied the upper limit rate in treaty.

this part need no prior approval from NTA!!


2. business profit
The impose authorities belong to 所得國. and the tax autority in sources country has only the right to clarify if it applied treaty or not.
this part need prior approval from NTA.