Enforcement Rules of the Tax Collection Act Article 6

For a profit-seeking enterprise which is dissolved upon a merger with or by another enterprise as referred to in Article 15 of the Law, if there is any tax refundable to it prior to such merger, the surviving or newly incorporated profit-seeking enterprise after the merger shall be entitled to receive such refundable tax; except for a sole proprietorship or a partnership whereby a separate agreement has otherwise been reached at the time of merger and such agreement has been reported to the tax collection authority for its recordation, in which event, such separate agreement shall prevail.