In view of increasing mergers and acquisitions undertaken by Taiwanese corporations for reorganisation purposes, the Ministry of Finance has recently released the tax ruling, Tai-Tsai-Shuei #9604545320, on October 3 2007. The tax ruling stipulates that when a company transfers its independently operated business to its 100% owned existing or newly incorporated subsidiary in exchange of the subsidiary's newly issued shares according to the Enterprise Merger and Acquisition Act and under the principle that the spin-off is not used as a tax avoidance device, the spun-off assets can be transferred at their book value, as the cost of share acquisition, to determine the property trading income/loss and the corresponding tax liability.
November 01 2007