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U.S. Senate Finance Committee Approves Bipartisan Legislation to Relieve Double-Taxation of Investments between the United States and Taiwan

19 September 2023

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Treaty Development

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United States-Taiwan

On 14 September 2023, the U.S. Senate Finance Committee approved bipartisan legislation to relieve the double-taxation of investments between the United States and Taiwan, the United States-Taiwan Expedited Double-Tax Relief Act. As previously reported, the legislation provides substantial benefits to Taiwan residents, similar to those that are provided in the 2016 United States Model Income Tax Convention. The provisions fall into four primary categories: Reduction of withholding taxes; Application of permanent establishment rules; Treatment of income from employment; and Determination of qualified residents of Taiwan, including rules for dual residents. The legislation requires full reciprocal benefits and does not come...