Offshore Banking Act Article 22-14

An offshore insurance branch may designate the head office of the same insurance enterprise or a branch of the same foreign insurance enterprise established inside the territory of the ROC that has been authorized by the CBC to conduct insurance-related foreign exchange businesses (the "designated branch") to handle the business activities set out in paragraph 1 of the preceding Article. The business handled by the designated branch shall be booked on the account books of the offshore insurance branch.The scope of businesses that the designated branch may handle includes cross-strait insurance businesses approved by the competent authorities in accordance with the Act Governing Relations between the People of the Taiwan Area and the Mainland Area. The control and supervision of such activities shall be handled in accordance with the regulations related to cross-strait insurance businesses. The offshore insurance branch shall coordinate and be responsible for such control and supervision.If the designated branch charges the offshore insurance branch reasonable fees for handling any of the offshore insurance branch's activities to pay for its operating expenses, such revenue shall be booked as the designated branch's income and be duly subject to taxation. If the designated branch does not charge the offshore insurance branch any such fees, the expenses for handling the offshore insurance branch's businesses shall not be booked as expenses.
中文原文 國際金融業務條例第22-14條
國際保險業務分公司得將前條第一項各款業務,委託經中央銀行許可辦理保險相關外匯業務之同一保險業總公司或同一外國保險業於中華民國境內設立之分公司(以下簡稱受委託機構)代為處理,受委託機構處理時,應帳列國際保險業務分公司。
前項受委託機構得代為處理之業務範圍,包括經金管會依臺灣地區與大陸地區人民關係條例許可辦理之兩岸保險業務;其控管作業應依兩岸保險業務往來相關規定辦理,並由國際保險業務分公司統籌負責。
受委託機構代為處理國際保險業務分公司之各項業務,向國際保險業務分公司收取合理對價以支應其營業費用者,該收入應列為受委託機構之所得,並依規定申報繳稅;受委託機構未向國際保險業務分公司收取對價者,其代為處理各項業務之費用,不得以費用列支。

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