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Taiwan Notice on Implementation of CFC Rules

10 October 2017

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Approved Changes

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Taiwan

On 20 September 2017, the Taiwan Ministry of Finance (MoF) published a notice that they will be implementing the CFC rules approved by the Legislative Yuan in July 2016. Key aspects of the CFC rules as provided in the notice are as follows: A foreign company located in a low-tax jurisdiction will be considered a CFC of a Taiwan company if the Taiwan company, together with related parties, directly or indirectly holds more than 50% of the foreign company's shares/capital or otherwise has significant influence (substantial management, control) of the foreign company; For CFC purposes, low-tax jurisdictions include jurisdictions where:...