- No change in percentage of ownership and investment structure upon migration
- Same legal personality to be maintained in the new jurisdiction
- No dissolution and liquidation procedures required in the original jurisdiction
- Carryover of retained earnings upon migration
It should be noted that the migration may be subject to anti-avoidance provisions if it is deemed to be an unreasonable business arrangement solely for purposes of avoiding or reducing Taiwan’s tax liability.
The Ruling provides clearer guidelines under which certain subsidiary migrations are treated as a tax-free event. It is recommended that Taiwanese companies review their restructuring plans and assess feasibility of applying the Ruling criteria.
EYG no. 001780-19Gbl
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