and Technical Service Fees Collected by Foreign Profit-Seeking Enterprises from the Manufacturing Industry, Technical Services Industry and Power-Generating Industry” (“Rules”)

 On January 29, 2014, the MOF and the MOEA jointly issued a ruling to amend the Rules. Highlights of the amendments are:

  1. the technical service fees paid to a foreign entity for “technical know-how” are no longer exempt from income tax;
  2. the royalties paid to a foreign entity for the use of “computer programs” can be exempt from income tax;
  3. limitations on the eligibility for tax exemption are loosened as to the scope of patent rights for which royalties are paid; and
  4. the amendments to the Rules took effect retroactively on January 1, 2011.