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Ruling on source of income from services

08 February 2008

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Approved Changes

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Taiwan

The Ministry of Finance issued a public ruling (Ruling No. 09604548020) on 7 December 2007 on the source of income from services. The ruling affirms the principle that income from the provisions of services outside Taiwan is non-Taiwan source income and therefore, not subject to Taiwan income tax, including withholding tax. This ruling specifically applies to the case where a Taiwanese biotech company outsources research, testing and conducting of trials to a Contract Research Organisation outside Taiwan.