According to the previous ruling rendered by the Ministry of Finance (“MOF”), for a shareholder who obtains shares by contributing technology in lieu of capital payment, income tax shall be levied on the amount which exceeds the cost and expense of obtaining the technology, and the cost and expense rate shall be 30% of the face value of the shares if relevant documents cannot be provided.  In order to resolve the situation where such shareholders are likely to pay the income tax before they have actually gained from selling such shares just because they are unable to prove the cost and expense, MOF promulgated a ruling on June 11, 2013.  Accordingly, for shareholders who obtain new technology as a result of the research project sponsored by the government or public research institutes and then transfer such technology to a non-public company to acquire the company’s shares, they could pay the income tax based on the review result after said sponsors convene a review committee to determine the amount of the cost and expense of such technology.