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【Cross-Border Tax】Taiwanese CFC tax ruling to impact offshore trustees

【Translated by HW Group】

The ruling has retrospective effect from 1 January 2024, because it is linked to the January 2024 decree imposing alternative minimum tax on the settlor and beneficiaries of offshore trusts when a CFC is involved. That decree stated that shares or capital held by the settlor through an offshore trust must be included in the calculation of an individual's direct shareholdings, for the purposes of taxing a CFC.

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