Regulations Governing Application of the Place of Effective Management Article 8

Starting from the date following its filing date, registration date, or the end of the prescribed time limit under articles 4 through 6, a foreign profit-seeking enterprise eligible under Article 43-4 of the Income Tax Act shall be deemed as a profit-seeking enterprise incorporated according to the Republic of China’s laws, and shall recognize the payment of various kinds of income derived from sources in the Republic of China in accordance with Article 8. The responsible person under articles 4 through 6 shall act as the tax withholder, and shall withhold income tax from various income payments, submit and issue the withholding (exemption) certificates in accordance with Articles 88, 89, 92, and 94-1 of the Income Tax Act. If the foreign profit-seeking enterprise distributes dividends or earnings to its shareholders, it shall submit and issue the dividend vouchers in accordance with Article 102-1 of the Income Tax Act.The term "profit-seeking enterprise incorporated according to the Republic of China’s laws" in the preceding paragraph shall include the sole proprietorship, partnership, company, cooperative, limited partnership, and profit-seeking entity in any other form of organization incorporated according to laws and regulations of the Republic of China.Starting from the date following its filing date, registration date, or the end of the prescribed time limit, any earnings which are subject to tax under Article 43-4 of the Income Tax Act and are distributed to shareholders by the foreign profit-seeking enterprise in the first paragraph shall be treated as income derived from sources in the Republic of China.