1.The foreign enterprise, institution, organization or association has no fixed place of business within the territory of the ROC.

2.The foreign enterprise, institution, organization or association has a qualification of business registration or similar business registration approved by the competent authority in the country where the head office of the enterprise, institution, organization or association is located. However, conformance to any one of the following circumstances is excluded:

（1）Where the foreign enterprise, institution, organization or association is exempted from business registration or   similar business registration in accordance with the tax law of the country where the head office of the enterprise, institution, organization or association is located.

（2）Where there is no business tax or similar taxes levied in the country where the head office of the enterprise, institution, organization or association is located. Such foreign enterprise, institution, organization or association shall have a certificate of registration or permit for establishment approved by the competent authority of the country.

3.The country where the head office of the enterprise, institution, organization or association is located provides reciprocal treatment or exempts similar taxes.