If a case satisfies more than one of the requirements of for the above strategies, the following additional issues are often taken into consideration:
| ITA 25 | Tax Treaties | Exemption for royalties | |
|---|---|---|---|
| Benefit | Reduced 3% withholding rate | Reduced withholding rate or exempted | Exempted |
| Required time, cost, and effort | Low | High | High |
| Uncertainty | Low | High | High |
| Time to apply -Option 1. Pay regular 20% withholding tax first and apply for a reduced rate later. After obtaining the approval for the reduced rate, then proceed to apply for tax refund. -Option 2. Apply in advance for the reduced rate and pay by the reduced rate directly. | Both option 1 and 2 are available. | Usually only option 1 is available because the application requires the evidence of service provision and cannot be submitted beforehand. | Usually only option 1 is available because the application requires the evidence of service provision and cannot be submitted beforehand. |