The Financial Institutions Merger Act Article 13

Where the merger of Financial Institutions is approved by the Competent Authority, the Surviving Institution or the Newly Incorporated Institution may, when applying for amendment registration of the real estate owned by the Extinguished Institution, its movable properties that require registration and all encumbrances, directly process the registration against the certificate issued by the Competent Authority, without paying registration fees, in the following manner:1.The stamp tax and deed tax incurred by the merger shall be exempted;2.Transferred securities are exempted from securities exchange tax;3.Any goods or labor services transferred are deemed as not falling within the scope of imposition of business tax;4.Where the land assumed by the Extinguished Institution in accordance with Article 76 of the Banking Act is transferred to the Surviving Institution or Newly Incorporated Institution due to merger, the land value increment tax shall be exempted;5.If land owned by the Extinguished Institution is transferred along with the merger, except for land mentioned in the preceding subparagraph for which land value increment tax is exempted, after the present value of the land is decided upon examination in accordance with the Land Tax Act, the registration for transfer of the title to the land shall be effected, and the payable land value increment tax may be deferred and paid by the Surviving Institution or Newly Incorporated Institution until the land is transferred again. Upon bankruptcy or dissolution, the deferred land value increment tax shall be paid on a priority basis;6.The goodwill generated due to the merger may be equally amortized within 15 years when the income tax return is filed;7.Expenses incurred due to the merger may be recognized over a period of 10 years when the income tax return is filed;8.The losses from the sale of non-performing loans due to the merger may be carried forward over 15 years when the income tax return is filed.The Financial Institutions subject to merger referred to in the preceding paragraph may, with complete accounting books and vouchers for the year of loss and the year of reporting deduction, use the blue return referred to in Article 77 of the Income Tax Act or, if such books and vouchers have been audited and certified by the CPA and a tax return has been processed and the income tax paid, the Surviving Institution or Newly Incorporated Institution after merger may, upon filing business income tax return, deduct the loss provided in Article 39 of the Income Tax Act before the merger of such Financial Institutions, which amount shall be calculated based on the proportion of shares in the Surviving Institution or Newly Incorporated Institution held by the shareholders (members) of such Financial Institutions due to merger, and such amount shall be deducted from the net profit of the current year within ten years from the year on which the loss is incurred.The Surviving Institution or Newly Incorporated Institution may continue to assume any tax incentives the acquired assets or business are entitled to according to applicable laws that are not yet expired or deducted to the extent originally applicable to the part of the Extinguished Institution acquired by the Surviving Institution or Newly Incorporated Institution following the merger, and if any assumed tax incentives are required to comply with the conditions and standards as specified in applicable laws and ordinances, the Surviving Institution or Newly Incorporated Institution shall meet the same incentive conditions and standards after the assumption of the tax incentives.