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HMRC internal manual

Double Taxation Relief Manual

Taiwan: Residents

A person is a resident of Taiwan if, under the laws of that territory, they are liable to tax therein by reason of domicile, residence, place of management, place of incorporation or any other criterion of a similar nature. This is because Taiwan currently has a territorial system whereby residents are taxed only on income or capital gains arising in Taiwan.

If, in the future, Taiwan changes its territorial system to one where residents are liable on their full world-wide income then a person will have to be liable on this basis in order to qualify as a resident. (Article 4(2)).