Article 66-6 of the Income Tax Act had been amended. The new law regulates that, in the case of paying dividends or earnings to an individual shareholder (member) residing in the territory of the ROC, the real deductible amount should be 50% of the imputation tax credit. For fairness, Article 73-2 was also modified. It regulates that, in the case of paying dividends to an individual not residing in the territory of the ROC or any enterprise having its head office outside the territory of the ROC, the gross dividends or the gross earnings received containing any retaining earnings subject to a 10% surcharge of profit-seeking income tax, then half of the amount of the surcharged profit-seeking income tax may offset the amount of withholding tax on such dividends or earnings.