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Taiwan Clarifies De Minimis Test for Recognition of Investment Income Under CFC Rules

08 October 2024

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Approved Changes

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Taiwan

Taiwan's Ministry of Finance has issued a notice on the de minimis test that allows profit-seeking enterprises to not recognize investment income under the CFC Rules. --- De Minimis Threshold for Exemption Criteria under the Controlled Foreign Company (CFC) Rules The National Taxation Bureau of the Southern Area, Ministry of Finance (hereinafter "The Bureau") stated that, the Controlled Foreign Company (hereinafter "CFC") rules were implemented in the taxable year 2023. According to Paragraph 1, Article 5 of the Regulations Governing Application of Recognizing Income from Controlled Foreign Company for Profit-Seeking Enterprise (hereinafter "CFC Regulations"), if a CFC's current-year earnings do...