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Deloitte maintains its position as a top-tier tax advisory firm. Al Chang is the head of a tax team of 22 partners and more than 300 professionals. The cross-border service line remains active as usual. The team has seen an influx of Japanese companies ... [more]

Deloitte maintains its position as a top-tier tax advisory firm. Al Chang is the head of a tax team of 22 partners and more than 300 professionals. The cross-border service line remains active as usual. The team has seen an influx of Japanese companies establishing their manufacturing base in Taiwan. The firm is well known for its capabilities in transfer pricing, the department is led by Mike Chang.

Ping Gwo, Amber Li, and Andrew Hsu helped a US listed company obtain a one-time transfer pricing adjustment on its Taiwan affiliates for its 2010 controlled transactions in order for the Taiwan affiliate to conduct a downward transfer pricing adjustment. The tax official accepted the team's position and pre-approved the application as conforming with the Ministry of Finance's income tax and VAT criteria.

Chang, Jerry Tang, and Saint Shen successfully reclaimed withholding tax on dividends that were attributable to a depositary receipt (DR) investment. Reclaiming investment in ordinary shares tends to be much easier than DR investments. This is due to the difficulty for tax authorities, from just looking at the withholding tax statement, to verify whether the final beneficiary actually received the dividend and to establish the link between when the investee company distributes dividends and the ultimate receiver. The team was able to use information from the Taiwan Stock Exchange to illustrate to the authorities the link from depository institution to the ultimate DR holder. They ultimately helped their client claim back $173,000 in withheld taxes.

KPMG's tax department is led by Sherry Chang. The large team of 10 partners and 182 fee earners covers all areas of tax and a wide range of industrial sectors, especially information communications, entertainment and financial services. The firm regularly ... [more]

KPMG's tax department is led by Sherry Chang. The large team of 10 partners and 182 fee earners covers all areas of tax and a wide range of industrial sectors, especially information communications, entertainment and financial services. The firm regularly recruits team members from the National Tax Administration (NTA) to enhance their familiarity with internal operations and procedures and to strengthen their ties with the NTA.

The team was engaged to review a client's transfer pricing policy regarding its overseas operations in China. The client is a leading Taiwanese company in the computer components industry. Their Chinese affiliates came under transfer pricing scrutiny after fluctuating profits over a few years, as a result the client incurred double taxation after the tax investigation. The team helped minimise these risks by restructuring their transfer pricing policy to be in sync with the company's overall economic performance. The team resolved the affiliates' transfer pricing difficulties in China, helping to avoid double taxation of about $4 million.

In the past 12 months, KPMG's advisers also helped analyse a client's potential Taiwan income tax liability in the hypothetical event that the client closed their Taiwan entities. The advisers helped to structure and plan the year's net operating losses to reduce their tax liability.

The firm was also engaged in providing tax advice to a client had just concluded liquidation procedures. They successfully helped their client to apply for a VAT refund despite their client lacking substantial documents. This required the team to conjure and identify proof that their client had overlooked to justify the refund before the tax authority.

Howard Kuo has taken over from the experienced Steven Go as PwC's national tax leader. The team is affiliated with PuHua & Associates (PricewaterhouseCoopers Legal) which act as their legal counterpart. The law firm is highly regarded for its ability ... [more]

Howard Kuo has taken over from the experienced Steven Go as PwC's national tax leader. The team is affiliated with PuHua & Associates (PricewaterhouseCoopers Legal) which act as their legal counterpart. The law firm is highly regarded for its ability in M&A and tax dispute resolution services. During the year the team added Peter Su who is a tax lawyer who will focus on international tax, cross border issues, and US tax issues.

Elaine Hsieh provided tax advice to one of the largest multinational companies (MNC) in the consumer products industry on the first bilateral advance pricing agreement (APA) application in Taiwan. The success in this matter is viewed as an important milestone in the promotion of Taiwan's tax environment in respect of the mitigation of cross-border tax risks, and thus was welcomed not only by the taxpayer but also by the NTA and the taxpayer company.

After the Financial Supervisory Commission of the Executive Yuan required several leading foreign banks to convert their branches in Taiwan to subsidiaries, the team advised four out of five of the major banks with the successful conversion, saving significant tax costs in the process. These are the first few bank conversions to occur in Taiwan and the team believes their conversion method will become a benchmark for future conversions of this type in the banking industry.

Michael Wong leads the tax department at Baker & McKenzie where he focuses on dealing with tax affairs of high net worth individuals. Clients value the firm's extensive international network as it gives the practice the ability to advise many of Taiwan's ... [more]

Michael Wong leads the tax department at Baker & McKenzie where he focuses on dealing with tax affairs of high net worth individuals. Clients value the firm's extensive international network as it gives the practice the ability to advise many of Taiwan's largest corporations and international clients on a multijurisdictional basis. "Worldwide coordination and support as well as strong personnel in many locations," is the reason why one client uses them.

The team of three partners and seven tax professionals includes Dennis Lee, a corporate tax specialist, who is singled out by clients as having "significant industry experience and a very practical approach to issues, also very responsive".

The practice works to ensure that, in multijurisdictional M&A transactions, the individual operations in various countries comply with the structure proposed by the team. Besides cross-border tax matters, the team is well versed in Taiwanese corporate tax issues, often helping MNC in obtaining tax refunds or adjustments on various matters such as R&D tax credits and VAT.

Tax advisory work has increased over the past 12 months. Though the team also have strong capabilities in tax litigation, they have found that companies have not been as willing to litigate in recent times, which might explain the emphasis on planning and advisory matters.

Ernst & Young's tax leader is Heidi Liu, who has succeeded Bill Seto, now based in Hong Kong. Due to the increased economic activity between China and Taiwan, last year the group set up their China Service Group (CSG) led by Ann Shen. The CSG is supported ... [more]

Ernst & Young's tax leader is Heidi Liu, who has succeeded Bill Seto, now based in Hong Kong. Due to the increased economic activity between China and Taiwan, last year the group set up their China Service Group (CSG) led by Ann Shen. The CSG is supported by experienced specialists Chienhua Yang and Michael Lin, who will offer clients with China operations a seamless service across Taiwan. The CSG is another effort to provide clients with highly integrated cross border services as it will connect with the China office on China tax questions.

Sophie Chou, who focuses on transactional tax and controversy matters, has led a few landmark projects in the past year. She advised a client in challenging the tax authorities' decision to disallow the tax deduction of "allocated costs" that is granted under domestic tax law; $30 million was at stake here. Chou managed to justify the tax deduction without revealing the client's global transfer pricing model. The outcome of the dispute has significant implications for the financial services sector in particular, and could set a precedent for similar cases in the future.

George Chou has been the leader of the transfer pricing practice since its inception in 1994. The team now numbers 32 transfer pricing-only professionals. The authorities' focus over the past year on the taxation of intangibles, an area that is filled with ambiguity and complexity has meant the transfer pricing practice has been busy in making sure clients' documentation can be sufficiently justified to prevent any additional assessment and in defending clients' tax treatment of intangibles.

Josephine Peng, who is considered by market participants as one of the outstanding individuals in in Taiwan for tax controversy matters, leads the tax team of eight tax partners and 20 fee earners at Lee & Li. The team is regarded highly within the industry ... [more]

Josephine Peng, who is considered by market participants as one of the outstanding individuals in in Taiwan for tax controversy matters, leads the tax team of eight tax partners and 20 fee earners at Lee & Li. The team is regarded highly within the industry for its tax litigation practice and their knowledge of the financial services industry. "They are one of the best tax advisers in Taiwan with regards to financial services, their good and professional connections with the tax officials are valued," said one client.

Frank Lin and Peng represented a large hospital in contesting the tax authority's investigation as to whether the income of the hospital's physicians, who were not employed by the hospital, should have been classified as salary income and subject to higher income tax. Through negotiations with the tax authorities, Lee & Li advisers successfully persuaded tax authorities to cease future investigation, mitigating potential tax disputes for several thousand physicians and a significant amount of tax payable was avoided.

Peng and Leo Tsai obtained two favourable judgments from the Supreme Administrative Court in litigation about the allocation of head office management expenses, which would have entailed consequences for the amount of tax deductible. By doing so, the advisers changed the tax authority's long practice of rejecting all the allocation of head office management expenses claimed by taxpayers, and successfully entered into settlements with the authority on behalf of their client. The judgments obtained are expected to be used as a reference for future cases of a similar nature.

Tsar & Tsai is equipped to offer tax advice on domestic and international business transactions, as well as litigation and dispute resolution.Jennifer Lin and Judie Sun successfully challenged the tax bureau's method used to calculate non-taxable income ... [more]

Tsar & Tsai is equipped to offer tax advice on domestic and international business transactions, as well as litigation and dispute resolution.

Jennifer Lin and Judie Sun successfully challenged the tax bureau's method used to calculate non-taxable income on behalf of Princo Corporation, a hi-tech company. The case concerned their client's income tax implications arising from increasing capital to expand its business.

Lin and Emily Chen also successfully advised Hitachi in applying for exemption of income tax on patent licensing royalties' payable by various Taiwanese licencees.