21 July 2016

Taiwan issues final regulations on controlled foreign company rules and place of effective management

Taiwan's Legislative Yuan amended the Income Tax Act (ITA) on July 12, and introduced the controlled foreign company (CFC) rules, incorporating some of the recommendations provided in the Organisation for Economic Co-operation and Development's final report on Action 3. The amendment also provides criteria for determining a foreign company's place of effective management (PEM). Once the foreign company's PEM is deemed to be in Taiwan, the foreign company is subject to tax on its worldwide income.

A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details.

———————————————
ATTACHMENT

Full text of Tax Alert 2016-1263

Document ID: 2016-1263