On December 24, 2025, the Ministry of Finance (MOF) promulgated the amendments to Article 2-1 and Article 2-2 of the “Standards for the Exemption of Penalties for Misconduct in Taxation Affairs,” as well as the “Reference Table for Fines and Multiples of Punishments” (hereinafter referred to as the Penalty Reference Table) under Article 46-1 of the Tax Collection Act. The amendments loosen penalty exemption conditions and establish clearer and more proportionate penalty benchmarks to encourage compliance by Reporting Financial Institutions (RFIs).

The MOF stated that, to align with international standards for information transparency, Taiwan implemented the Common Reporting Standard (CRS) in 2017 pursuant to the provisions of paragraph 6 of Article 5-1 of the Tax Collection Act and has since refined the related penalty framework and inspection mechanisms, including assigning the National Taxation Bureaus (NTBs) as examination authorities in 2021.

Based on practical experience from documentary and on-site examination conducted by NTBs since late 2021, the amendments introduce the following key measures to loosen the existing rules:

1.        Penalty exemptions for all cases of erroneous reporting and for limited cases of non-reporting, providing that the related violation acts have been voluntarily corrected prior to notification by the NTB.

2.        Penalty exemptions for not performing the required due diligence procedures, providing that the RFIs have voluntarily completed the due diligence and corrected or supplemented reporting before receiving the NTB’s notification.

3.        Penalty exemptions for first-time cases even though the violations in those cases have been determined, provided that the RFIs have cooperated in completing the required curing compliance actions.

4.        Corresponding revisions to the Penalty Reference Table have been made to ensure penalties are clear, reasonable, and proportionate.

The MOF emphasized that the above-mentioned amendments will take effect on December 26, 2025. For cases pending final decisions on the identified violation acts that occurred before the effective date, the amended provisions will apply to these cases. However, if the provisions prior to the amendment are more favorable to the RFIs, such provisions prior to the amendment shall apply.

The MOF encourages RFIs to fulfill their CRS due diligence and reporting obligations, thereby strengthening the mechanism of Taiwan’s automatic exchange of financial account information, enhancing tax transparency, and safeguarding tax fairness.

Contact person: Mr. Chi-Luan Huang, Section Chief.

Contact Number: (02)2322-8183