(1) This Agreement shall apply to taxes on income and on capital gains imposed in either of the territories, irrespective of the manner in which they are levied.
(2) There shall be regarded as taxes on income and on capital gains all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property.
(3) The existing taxes to which this Agreement shall apply are in particular:
(a)in the territory in which the taxation law administered by the United Kingdom Inland Revenue is applied:
(i)the income tax;
(ii)the corporation tax; and
(iii)the capital gains tax;
(b)in the territory in which the taxation law administered by the Department of Taxation, Ministry of Finance, Taipei is applied:
(i)the profit seeking enterprise income tax; and
(ii)the individual consolidated income tax.
(4) This Agreement shall also apply to any identical or substantially similar taxes which are imposed in either territory after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the territories shall notify each other of any substantial changes which have been made in the taxation laws of the respective territories.