Income Tax Act Article 14-3

In case any individual person, profit-seeking enterprise, or organization or institution which is established for educational, cultural, public welfare or charitable purposes, is discovered to have improperly evaded or reduced the tax burden for himself/ herself/ itself or for other person(s) by means of transfer of funds or shareholder's equity, or any other false arrangement with any other domestic or foreign individual person, profit-seeking enterprise, or organization or institution which is established for educational, cultural, public welfare or charitable purposes, the tax authority for the purpose of computing the accurate amount of income and tax payable of the relevant taxpayers may, with the approval of the MOF, make necessary adjustment according to the facts of actual transactions of investigation in accordance with the relevant laws. If a company, cooperative, or other juristic person increase dividends or earnings distributed to shareholders, members, or investors through false arrangements or improper means that falsely increase the amount of tax credit set forth in Paragraph 4, Article 15, the tax authority may, based on the information acquired during investigation, make necessary adjustment in accordance with the amount of dividend or earnings payable to or received by such individual person.