US, Taiwan to begin negotiating comprehensive tax deal to combat double taxation

WASHINGTON, DC The U.S. Department of the Treasury today announced that the United States and Taiwan, under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO ), would begin negotiations on a comprehensive agreement to resolve double taxation issues. The first round of negotiations is expected to take place in the coming weeks.

This action builds on the leadership demonstrated by Congress, which remains a critical partner in resolving this problem. The Biden-Harris Administration recognizes the work being done by House and Senate committees to address the issue of double taxation, including through the proposed U.S. Accelerated Double Taxation Relief Act. and Taiwan and the U.S.-Taiwan Tax Agreement Authorization Bill. legislation. The Administration is committed to collaborating with relevant committees throughout the negotiation process and to working with Congress on legislation to approve a final agreement and to implement the agreement through the Internal Revenue Service. Code.

A comprehensive tax deal will bring key benefits to both the United States and Taiwan. In particular, this action will support the goals of CHIPS and the Science Acts to strengthen the resilience of the semiconductor supply chain, create jobs, and encourage investment in semiconductor manufacturing facilities across the United States. This will reduce double taxation barriers for new investments from Taiwan to the United States, and vice versa, especially for small and medium-sized businesses that are essential to a comprehensive semiconductor ecosystem.

The text should be based on the US model tax treaty and include elements such as:

Reduction of withholding taxes on cross-border payments of dividends, interest and royalties; Provisions governing permanent establishments and the tax treatment of temporary cross-border workers; Modern anti-abuse provisions intended to prevent cases of non-taxation of income as well as forum shopping; dispute resolution mechanisms; and provisions for the exchange of information to assist the tax authorities of both jurisdictions in carrying out their functions as tax administrators.

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