FINI Tax Advisory
Foreign Institutional Investors (FINI) investing in Taiwan often face complex tax considerations relating to dividends, withholding tax, treaty eligibility, refund mechanisms, and documentation coordination with custodian banks.
LY CPA provides specialized advisory support to help global investment institutions understand Taiwan’s tax requirements and complete the necessary procedures efficiently and with full transparency.
Key Tax Considerations for FINI Investors
Dividend Withholding Tax (WHT)
Standard statutory rate: 20%
Potential reduction to 10–15% under applicable Double Tax Treaties
Treaty rates require filing and supporting documentation; they are not automatic
Interest Income Withholding
Depends on the nature of the instrument
Bonds, REITs, structured notes, and derivatives require case-by-case analysis
Source of Income Rules
Capital gains on listed securities are generally non-Taiwan-sourced
Dividends are Taiwan-sourced and subject to WHT
Refund Eligibility and Deadlines
Refund applications may be filed within 10 years
Supporting documents include WHT statements, TRC, investment records, and custodian confirmations
Custodian Bank Coordination
FINI structures often involve multiple custodians
Document requirements and formatting vary
Professional support ensures smoother processing and reduces delays
Our FINI Support Services(Note):
1. Tax Documentation and Procedure Support
Assistance with understanding FINI tax requirements
Guidance on documentation preparation and regulatory expectations
Support in communicating with custodian banks or intermediaries
2. Dividend and Interest WHT Reduction Applications
Eligibility assessment under applicable tax treaties
Review of withholding statements and supporting documents
Preparation of application materials for submission by investors or custodians
3. Double Tax Treaty (DTA) Application Support
Review of Tax Residency Certificates (TRC)
Assessment of treaty eligibility
Preparation of supporting explanations and documentation packages
4. Refund Application Support
Guidance on refund eligibility and required documents
Preparation of refund explanations and supporting materials
Progress monitoring and follow-up support
5. Support for Specialized Institutional Structures
Sovereign wealth funds
Government pension funds
Master-feeder structures
ETFs, derivatives, and structured products
6. Custodian Bank Liaison Support
Coordination with Citi, HSBC, Standard Chartered, CTBC, E-Sun, and others
Document standardization
Clarification of tax-related requirements to reduce processing time
Note:
Due to internal risk management policies, we are unable to act as the official tax filing or tax payment agent in Taiwan where such appointment would render us jointly and severally liable for any and all taxes, penalties, or interest that may arise during the engagement period.
However, as we are well-positioned to assist with above-mentioned services, we remain committed to assisting foreign institutional investors with navigating Taiwan’s tax landscape efficiently while managing risk responsibly.
Service Workflow (Timeline)
| Stage | Description | Typical Timeline |
|---|---|---|
| Initial Review🗂 | Review of investor structure and documents | 3–5 days |
| Document Compilation📄 | Collection and review of supporting materials | 1–2 weeks |
| Application Package Preparation📨 | Preparation of treaty/WHT/refund documentation | 2–4 weeks |
| Review by Tax Office🏛 | Follow-up, clarification, supplemental documents | 1–3 months |
| Completion🔁 | Decision issued and refund processed (if applicable) | Case-specific |
Why Global Institutions Work With Us?
Big Four International Tax Background
Over ten years of experience advising cross-border institutional investors.
Deep Knowledge of Taiwan Treaty Relief and Article 25/15-1 Practice
Clear understanding of tax authority expectations and practical interpretations.
Strong Coordination Capability with Custodian Banks
Efficient communication and streamlined document preparation.
Dedicated Focus on FINI, Foreign Investors, and Cross-Border Issues
Bilingual communication, institutional reporting standards, and a risk-conscious advisory approach.
