To prevent any multinational enterprise or individual from establishing a controlled foreign company (CFC) in a low-tax jurisdiction to retain earnings in the CFC for tax avoidance, Article 43-3 of the Income Tax Act and Article 12-1 of the Income Basic Tax Act were promulgated to set the CFC rules for enterprises and individuals on July 27, 2016 and May 10, 2017, respectively. The enforcement date of these rules shall be determined by the Executive Yuan.
To follow the international trend and reinforce sound anti-avoidance systems, the Executive Yuan designated that the CFC rule shall be enforced from the 2023 taxable year for enterprises and January 1, 2023 for individuals.
To implement the CFC rules smoothly, the Ministry of Finance has released detailed regulations and designed operating procedures. The information is available at the website of the Taxation Administration, Ministry of Finance (https://www.dot.gov.tw/Eng) “Home > Tax Reform > Anti-tax Avoidance Rules > CFC Rules for Enterprises or CFC Rules for Individuals.”
Press Release Contact: Mr. Liu, Senior Executive Officer