Executive summary

On 10 September 2025, Taiwan's Ministry of Finance issued the "Directions for the Levy of Business Tax on Individuals Regularly Publishing Creative or Informational Content Online" (Influencer Value-Added Tax (VAT) Guidelines). Per the Value-Added and Non-Value-Added Business Tax Act (Business Tax Act), the Influencer VAT Guidelines establish standardized procedures for VAT registration and VAT filing for both domestic and foreign individuals who regularly publish creative or informational content online (collectively referred to as "influencers"), as well as for domestic or foreign platforms that utilize such content through advertising or paid services.

Currently, the advertising fee and paid e-commerce income (e.g., subscription fees) that foreign platforms generate from domestic viewers, as well as the revenue sharing income that foreign influencers generate from domestic viewers via platform, are subject to Taiwan VAT at the rate of 5%, applicable to different foreign taxpayers in different transaction models.

Definitions and determination of relevant terms

• Domestic advertisers and viewers refer to any of the following:
• Non-individuals: Enterprises, institutions, organizations or groups that have a fixed-place business (FPB) in Taiwan, regardless of whether they engage in the sale of goods or services
• Individuals: Individuals with a residence or domicile in Taiwan, whose computer equipment or mobile devices are installed in Taiwan, whose mobile device's phone number area code is 886, or who provide other relevant information that can determine them as individuals in Taiwan (e.g., billing address, IP address, etc.)
• Foreign platform: Platforms that do not have an FPB within Taiwan
• Foreign influencers: Influencers that neither have an FPB in Taiwan nor meet the criteria of domestic individuals listed under Domestic Advertisers and Viewers
• Foreign advertisers and viewers: Advertisers and viewers who do not meet the criteria of domestic advertisers and viewers
• Paying viewers: Viewers who purchase related paid services (e.g., paid subscriptions) from platforms

Taxation principles, tax rates and taxpayers

Foreign platforms that receive advertising fee from advertisers:

Foreign platforms that receive e-commerce income from viewers:

Foreign influencers who receive revenue-sharing income from platforms:

Note 1: Because non-paying viewers are the ultimate users of the advertising services, the transaction would be considered a foreign platform selling e-commerce services to domestic individuals (with the service fee being paid by advertisers on behalf of individuals); therefore, the foreign platform would be deemed the taxpayer under the current VAT Act and Influencer VAT Guidelines.

Note2: To simplify cross-border tax administration, foreign influencers are exempt from VAT registration, filing and payment, as input tax generated from purchasing foreign influencer's services by foreign platforms can be credited against foreign platforms' output tax.

The Ministry of Finance stated that the Influencer VAT Guidelines represent a new taxation system for emerging transactions. Considering that influencers and platforms might not have a clear understanding of the relevant regulations during the initial implementation phase, violations of the Influencer VAT Guidelines may be waived from 10 September 2025 to 30 June 2026 (hereinafter referred to as the "grace period").

Implications

With the rapid development of the digital economy, the transaction models of influencers and platforms are becoming increasingly complex, involving multiple parties, such as domestic and foreign influencers, platforms, advertisers and viewers. The Influencer VAT Guidelines provides affected parties with clearer guidelines on the tax obligations (including tax rates and filing method) to be imposed on all parties involved based on the transaction parties and locations.

However, the Influencer VAT Guidelines also generate several issues worth discussing. For example, foreign platforms may face technical challenges in effectively identifying viewers' locations. In addition, foreign influencers receiving revenue-sharing income from the platforms will find that when this income is derived from domestic platforms and the content is viewed by domestic viewers, the transaction is now subject to Taiwan VAT. Moreover, although foreign influencers currently are exempted from Taiwan VAT registration, filing and payment, close attention should be paid to any future amendments to the Influencer VAT Guidelines or issuance of new Taiwan regulations.

Overall, although the Influencer VAT Guidelines enhance tax-management transparency and establish a basis for VAT registration and VAT filing related to influencers' transaction models, platforms and influencers should review their sources of income, clearly categorize transaction types and parties, and establish mechanisms to identify the locations of transaction parties. Taxpayers making cross-border transactions should consider utilizing the grace period for preparation in advance and consult professional tax advisors to identify and address potential risks.

Finally, note that the Taiwan tax authority has already issued a Tax Ruling No. 10600549520, which governs VAT registration, filing and payment obligations for foreign e-commerce operators (e.g., foreign platforms under the Influencer VAT Guidelines) that do not have an FPB in Taiwan and render e-commerce services (e.g., advertising service or paid e-commerce service) to domestic individuals. According to the ruling, if foreign platform's annual B2C sales amount currently exceeds 600,000 New Taiwan Dollars (NTD600k) (i.e., approximately US$20k), the platform must conduct VAT registration and file VAT returns accordingly.