Taxpayers of the business tax are as follows:
1. Business entities that sell goods or services.
2. Consignees or holders of imported goods.
3. Purchasers of services provided by foreign enterprises, institutions, groups, or organizations that have no fixed place of business within the territory of the R.O.C.; however, in the case of foreign international transport enterprises that have no fixed place of business within the territory of the R.O.C but have agents in the ROC, the taxpayers are the agents. 
4. If the agricultural or fishery fuel oil referred to in Article 8, paragraph 1, subparagraph 27 or 28 herein loses tax-exempt status due to a transfer or to a change in the purpose of use, the taxpayer is the transferring party or the party that changes the purpose of use; however, in the event that the transferring party or the party that changes the purpose of use is unknown, the taxpayer is the holder of the goods.