I dont know that you have answered my question, but that may because I don't know some of the technical terms (e.g. What is the difference between domicile and resident? What does 'taxable to her' mean) so I'll try to be more specific.
The plan is to transfer the money to a bank account that she already has in the UK (she studied here and kept the account open so she could access cash easily when visiting). Can the government tax any of the transferred money when it is electronically deposited into the bank account from Taiwan? A bit like the import duty I ended up paying on a birthday present she sent from China.
I could do with some help translating the following into ordinary English "The profits of an enterprise of a territory shall be taxable only in that territory unless the enterprise carries on business in the other territory through a permanent establishment situated therein"
What is meant by "enterprise" in the above? Is this a person or a business or the stuff a person does to make a living when self-employed or something else? In relation to the previous question what does a 'permanent establishment' mean
Once she is living here I presume she will have to pax tax on "earnings", (e.g. on interest earned on the capital, salary, profits from business etc.) but I can't work out from what you have written whether she is liable to pay tax on the capital itself. "Until she is a resident or sets up her business in the UK the money would not be taxable to her." is rather ambiguous in this respect. She is going to be here, hopefully with a business, so does that mean she will or will not have to pay tax on the capital she has transferred into the country?