On 12 July 2016, Taiwan’s Ministry of Finance announced that the Legislative Yuan has adopted anti-avoidance amendments to the Income Tax Act, including new controlled foreign company (CFC) rules and new rules for the determination of place of effective management (PoEM) for foreign companies.
CFC Rules
Under the new CFC rules, a foreign company located in a low-tax jurisdiction will be considered a CFC of a Taiwan company if the company together with related parties directly or indirectl…