Ministry of Finance releases triangular merger regulations

The Ministry of Finance has issued a Ministerial Ordinance on 13 April 2007 with regard to the tax treatments of triangular mergers, which will apply as of 1 May 2007.

Triangular mergers are presumed to occur when a domestic company owned by a foreign parent company merges with a "target" domestic company by giving shareholders of the target company shares in the foreign parent company as consideration for the shares in the target company. This is because the cu…