11 April 2019 Taiwan issues tax ruling on corporate migration Taiwan's Ministry of Finance issued a ruling (the Ruling) that provides conditions under which a Taiwanese parent company would be exempt from gain recognition when a subsidiary migrates its place of company registration from one jurisdiction to another. To fall under the exemption, all of the following conditions must be met:
It should be noted that the migration may be subject to anti-avoidance provisions if it is deemed to be an unreasonable business arrangement solely for purposes of avoiding or reducing Taiwan's tax liability. The Ruling provides clearer guidelines under which certain subsidiary migrations are treated as a tax-free event. It is recommended that Taiwanese companies review their restructuring plans and assess feasibility of applying the Ruling criteria.
Document ID: 2019-0754 |
