1. Individual Controlled Foreign Company (CFC) Rules are enforced from January 1, 2023. If an individual directly or indirectly holds shares or capital of a foreign affiliated enterprise in a low-tax country or jurisdiction, please refer to “Statement of The Shareholding of An Individual and of His/her Related Parties” to determine the applicability of Individual CFC Rules.
2. If the individual and his/her related parties directly or indirectly hold 50% or more of the shares or capital of such a foreign affiliated enterprise, or had control over it, the individual shall file “Statement of The Shareholding of An Individual and of His/her Related Parties” (including the Attachment: The Organization Chart) and submit with “Individual Income Tax Return of the Republic of China”.
3. Where the individual himself/herself, with his/her spouse or relatives within the second degree of kinship directly holds 10% or more of the shares or capital of such a CFC on December 31, 2025; or directly holds below 10% of the shares or capital, but the CFC has current-year losses that would be deducted in the following years, please fill out “Business Income Statement of a Controlled Foreign Company (CFC) for Individual” and submit with related proof documents.