If a foreign investor has received dividends from a foreign-invested company eligible for tax deduction, is the basis for withholding tax the domestic tax rate pursuant to the tax law or the restrictive tax rate pursuant to the tax agreement?

The withholding tax is selected from whichever is lower among the two tax rates.
What is the restrictive tax rate?

– The restrictive tax rate is a tax rate agreed upon through a tax agreement, which does
not permit the taxation above a certain maximum rate for investment profits such as
interest, dividend or fees.