BUSINESS MERGERS AND ACQUISITIONS ACT Article 47

Between a company and its subsidiary company, between a company or its subsidiary company and any domestic or foreign individual, profit-making business or education, culture, public interest, charities or organization, if there is one of the following situations, the tax collection authorities may seek the approval from the Competent Tax Authority to readjust such tax obligations either according to the arm's length transaction or depending on the results of investigation in order for an accurate computation of the income tax and tax payable of the tax payer:1.Any arrangement not made in arm's length transaction, avoidance or reduction of tax obligation on the amortized income, expenses, expenditures and profit/loss;2.Any improper avoidance or reduction of tax obligation for oneself or for any other person by means of the acquisition of equity, transfer of assets or any other fraudulent arrangement.Any company or its subsidiary company when subject to a recompilation of the amount of income and the taxable amount by the tax collection authorities pursuant to the preceding paragraph hereof is prevented from filing a combined business income tax as provided in Article 45.