{{item.videoDuration}}
{{item.title}}
{{item.text}}
{{item.videoDuration}}
{{item.text}}
Cross-border Tax Talks
June 19, 2026
Taiwan Update: Treaties, Tariffs and Top-Up Tax Turbulence
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Paulson Tseng, PwC Taiwan’s International Tax Services and Transfer Pricing Leader, the firm’s Human Capital Leader, and host of the Finance and Tax Cafe podcast.
Doug and Paulson discuss Taiwan’s corporate tax framework, including the 20% corporate rate, foreign tax credit limits, withholding tax friction for services, and CFC rules; how inbound investment remains strong in semiconductors and R&D while outbound models are shifting toward more diversified, multi-nodal footprints; Taiwan’s current Pillar Two posture, top-up tax exposure, and readiness challenges around data, education, and compliance; whether Pillar Two is already changing business behavior; tax controversy themes in Taiwan, especially transfer pricing, withholding tax, and risk-based audits; and Paulson’s own podcast and its broader finance, economic, and workplace-stress topics.
- [00:45] – Setting the scene in Hong Kong and introducing the guest; a quick Mizzou detour
- [02:50] – What does Paulson focus on in Taiwan’s international tax market?
- [03:40] – An overview of Taiwan’s corporate tax system
- [05:00] – What are the main withholding tax rules and treaty constraints, including service fee payments?
- [07:30] – How do Taiwan’s CFC rules work?
- [10:25] – Taiwan’s current inbound and outbound investment environment.
- [12:50] – How are tariffs and geopolitics reshaping Taiwanese supply chains?
- [15:20] – Why is US manufacturing attractive, and what practical barriers remain?
- [18:00] – Where does Taiwan currently stand on Pillar Two implementation?
- [20:20] – Why is QDMTT the likely first move, and what happened to the 15% domestic minimum tax idea?
- [22:15] – How much top-up tax are Taiwanese multinationals already seeing?
- [24:00] – How ready are Taiwanese companies for Pillar Two compliance?
- [25:35] – Are companies using centralized or decentralized data collection models?
- [27:40] – Is Pillar Two changing behavior and pulling functions back to Taiwan?
- [32:10] – What tax controversy trends are emerging in Taiwan?
- [34:20] – Why did Paulson launch Finance and Tax Cafe, and how has it evolved?
Speakers
International Tax Services Global Leader, PwC US
Paulson Tseng
Follow us
