Tax Related Laws & Regulations

Tax Act：

Regulations Governing Application of Calculating Income from Controlled Foreign Company for Individual
Article　4

Content：

The term "low-tax jurisdiction" referred to in Article 2 shall mean the country or jurisdiction of affiliated enterprises who meets any of the following conditions:

1. The statutory tax rate of the profit-seeking enterprise income tax or substantially similar tax in the affiliated enterprise’s country or jurisdiction is not more than 70% of the tax rate prescribed in Subparagraph 2, Paragraph 5, Article 5 of the Income Tax Act.

2. The affiliated enterprise’s country or jurisdiction taxes only on income sourced from it, and foreign-sourced income is either not taxed or is taxed only upon actual remittance.

For a country or jurisdiction that applies a specific tax rate or tax regime to a given region or type of enterprise, such specific tax rate or regime shall be considered in the determinations under the preceding paragraph.

The Ministry of Finance shall announce a reference list of low-tax jurisdictions prescribed in the first paragraph.

Update：2024-04-19

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