The Taipei National Tax Administration (TNTA) recently issued a private ruling on the source of income of securities brokers who engage in foreign securities transactions. Under the current rules, a domestic broker acts as an intermediary between clients and foreign brokers and only earns a spread from the foreign transactions. Prior to the issuance of the private ruling, it was unclear whether the income earned by the foreign broker was Taiwanese-sourced income. Therefore, the private ruling was issued to set-out the TNTA's position, and illustrates the business tax and income tax implications of the foreign securities transactions for both the...