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U.S. Senate Finance Committee Approves Bipartisan Legislation to Relieve Double-Taxation of Investments between the United States and Taiwan — Orbitax Tax News & Alerts

On 14 September 2023, the U.S. Senate Finance Committee approved bipartisan legislation to relieve the double-taxation of investments between the United States and Taiwan, the United States-Taiwan Expedited Double-Tax Relief Act. As previously reported, the legislation provides substantial benefits to Taiwan residents, similar to those that are provided in the 2016 United States Model Income Tax Convention. The provisions fall into four primary categories:

  1. Reduction of withholding taxes;
  2. Application of permanent establishment rules;
  3. Treatment of income from employment; and
  4. Determination of qualified residents of Taiwan, including rules for dual residents.

The legislation requires full reciprocal benefits and does not come into full effect until Taiwan provides the same set of benefits to U.S. persons with income subject to tax in Taiwan, similar to the reciprocal operation of a tax treaty. Any further developments with the legislation will be reported once available.

Click the following links for statements on the legislation from Committee Chairman Ron Wyden (D-OR) and Ranking Member Mike Crapo (R-ID).