Enforcement Rules of the Income Tax Act Article 83-1

Where the trustee in a trust act invests the trust property in a profit-seeking enterprise, the said profit-seeking enterprise shall name the said trustee as the taxpayer, and shall thus issue to the beneficiary a dividend voucher (warrant) in accordance with the provisions set out in Paragraph 1, Article 102-1 of the Act.The trustee referred to in the preceding paragraph shall, based on the dividend amount or the earning amount distributed to it and in accordance with the provisions set out in Paragraph 1, Article 3-4 of the Act, calculate the amount of income receivable by the beneficiary, and shall further, within the time limit specified in Article 92-1 of the Act, fill out and issue to the beneficiary a dividend voucher (warrant), whereas, if there are two or more beneficiaries involved, the said trustee shall, in accordance with the distribution ratios as specified in Paragraph 2, Article 3-4 of the Act, calculate respectively the amount of income receivable for each individual beneficiary.Where the beneficiary referred to in the preceding paragraph is an individual person not residing in the territory of the Republic of China or a profit-seeking enterprise whose head office is located outside the territory of the Republic of China, then the said trustee shall, in accordance with the provisions set out in Paragraph 3, Article 89-1 of the Act, withhold the income tax from the amount of income payable to the beneficiary by the said trustee; and shall further issue to the said beneficiary a withholding tax voucher (certificate) in accordance with the provisions set out in Article 92-1 of the Act, and will be exempted from issuing the dividend voucher (warrant).
中文原文 所得稅法施行細則第83-1條
信託行為之受託人以信託財產投資於營利事業者,該營利事業應以受託人為納稅義務人,依本法第一百零二條之一第一項規定填發股利憑單。
前項受託人應將獲配之股利或盈餘,依本法第三條之四第一項規定計算受益人之所得額,於本法第九十二條之一規定期限內,填發股利憑單予受益人;受益人有二人以上者,受託人應依本法第三條之四第二項規定之比例計算各受益人之所得額。
前項受益人為非中華民國境內居住之個人或總機構在中華民國境外之營利事業者,受託人應就前項所得額,依本法第八十九條之一第三項規定辦理扣繳,並依本法第九十二條之一規定填發扣繳憑單,免填發股利憑單。

English translation for reference only; the Chinese text prevails. Not legal advice.