Taiwan Stamp Tax for Foreign-Owned Subsidiaries: Contracts, Receipts and Where You Sign

"Our parent signed the services agreement in California, so it isn't a Taiwan document." That belief breaks down once the Taiwan subsidiary signs in Taipei. Taiwan's Ministry of Finance (MOF) treats a contract between a Taiwan company and a foreign company as written in Taiwan when the Taiwan company signs it in Taiwan, no matter which side signed first (MOF ruling of February 9, 1985). Being in the same group does not help either. The exemption for internal paperwork covers a head office and its branches, and a subsidiary is not a branch (Stamp Tax Act, Article 6; Enforcement Rules, Article 5).

Stamp tax (印花稅) is a tax on documents. It reaches only documents written (書立) within Taiwan's territory (Article 1), and only four kinds of them (Article 5). Paying it traditionally means buying revenue stamps issued by the MOF and sticking them on the paper (Article 2). Payment slips and lump-sum approvals come from the local tax office where the company is located (eTax portal).

Four documents, four rates

As of October 2026, Article 7 of the Stamp Tax Act (last amended May 15, 2002) sets these rates:

The NT$12 figure needs a word of explanation. Article 7 says "4 yuan." Article 3 denominates the Act's amounts in the national currency (國幣), and Article 2 of the Act Governing the Conversion of Currency Units Used in Existing Laws and Regulations into New Taiwan Dollars, announced July 17, 1992, converts each yuan into three New Taiwan dollars. The MOF's eTax portal therefore lists NT$12 per document.

Contracts for work are those in which one party completes a specified task for the other. Article 5 names construction, printing and processing contracts as examples. Substance decides, not the heading. A quotation or delivery note used in place of a contract is stamped according to what it really is, and a document with two natures carrying different rates takes the higher one (Article 13, paragraphs 1 and 3).

One equipment deal, priced two ways

A US test-equipment maker's Taiwan subsidiary sells a customer in Hsinchu a system for NT$6 million and agrees to install and calibrate it for NT$1.5 million (an invented example). Put both in one contract and the whole NT$7.5 million is taxed as a contract for work at 0.1%: NT$7,500. Sign a sales contract and a separate installation contract instead, and the stamps come to NT$12 plus NT$1,500, or NT$1,512. That is NT$5,988 less. The MOF's tax-saving page on eTax walks through the same split using an elevator purchase and installation.

Those figures are per copy. When two or more originals are made and each party keeps one, every original needs its own stamps (Article 12). Each party answers for the copy it holds (eTax Q&A, item 7).

When the tax is due and how to pay

Article 8 requires full stamps when a document is delivered or used after it is written. Performance is irrelevant. A contract that is signed, delivered and later terminated gets no refund (eTax Q&A, item 8). Amounts stated in US dollars or Vietnamese dong are converted into New Taiwan dollars at the government-prescribed or approved exchange rate at the time of delivery or use (Article 17).

There are three ways to pay:

1. Buy revenue stamps at a post office, stick them on, and cancel each one with the company seal across the edge of the stamp and the paper; only an individual may sign instead of sealing (Article 10; eTax portal).
2. For a large amount, ask the tax office for a payment slip (繳款書) instead (Article 8, paragraph 1). According to the eTax portal, a company can issue the slip online with an electronic certificate such as its business certificate (工商憑證), pay, and stick the proof-of-payment portion on the contract.
3. A company with many taxable documents can apply to its local tax office for lump-sum payment (彙總繳納) (Article 8, paragraph 2). Each period covers two months. By the 15th of January, March, May, July, September and November, the company computes and pays the tax itself and files a lump-sum return by the same date (Regulations for Lump-Sum Payment of Stamp Tax, Article 5).

Uniform invoices, cheques and branch paperwork

Uniform invoices (統一發票) issued by the subsidiary are not taxable money receipts, because Article 5(2) excludes receipts that double as business invoices. Business tax and uniform invoices are covered in Business Tax for a New Taiwan Subsidiary. When payment comes by cheque, draft or promissory note, a receipt stating the instrument's name and number needs no stamps. Cash is different. A receipt for NT$500,000 received in cash carries NT$2,000 in stamps at 0.4% (eTax tax-saving page).

Documents used between a head office and its branches that create no rights or obligations toward outsiders are exempt (Article 6, item 3). Subsidiaries fall outside this. Article 5 of the Enforcement Rules of Stamp Tax Act says an independent entity set up as an equity investment is not treated as a branch. The Hsinchu City tax bureau's training slides put it plainly: parent and subsidiary are separate legal persons, so a taxable document between them bears stamp tax. For how the two structures differ more broadly, see Entering the Taiwan Market: Key Differences Between a Subsidiary and a Branch.

Signing in two countries

Who signs first does not matter to the MOF. Its ruling of February 9, 1985 (台財稅第11750號函, in the MOF rulings database) dealt with a technical-services contract for work between a Taiwan company and a foreign enterprise. Whether the Taiwan company signed first and sent the contract abroad, or the foreign party signed abroad and sent it in, the Taiwan company signed in Taiwan, so the contract was a document written in Taiwan and needed stamps. A Vietnamese parent that signs first in Ho Chi Minh City is in the same position under that reasoning.

What if both sides sign abroad? The Taichung City local tax bureau says a contract for work written by both parties abroad falls outside the tax (updated September 20, 2024). The Taipei City tax office adds a warning in its FAQ: where the parties choose to sign outside Taiwan to obtain a tax benefit, abusing the legal form to avoid stamp tax, the local tax office should treat it as tax avoidance under the Taxpayer Rights Protection Act and assess the tax (updated January 21, 2026).

E-signatures: what the official record shows

One MOF ruling deals with electronic contracts. Dated July 9, 2015 (台財稅字第10404573930號令, MOF rulings database), it covers government procurement contracts that an agency and the winning bidder sign by e-signature on the government e-procurement system: they are documents written in Taiwan and fall under the Stamp Tax Act. The Taipei City tax office repeats this in another FAQ (updated February 18, 2022).

Private contracts are a different story, and an untidy one. The MOF's 2022 compilation of stamp-tax rulings, as searched on October 6, 2026, contains no ruling that exempts e-mail or e-signature contracts between companies, and none that taxes them. An e-signed services agreement with a US or Vietnamese parent therefore sits in a gap. For a large contract for work, ask the local tax office before relying on either answer.

Penalties

Fines are multiples of the tax. An unstamped or under-stamped document must be made up with stamps, plus a fine of 5 to 15 times the missing tax (Article 23, paragraph 1). Stamps left uncancelled or cancelled improperly draw 5 to 10 times their value, and stamps peeled off and reused draw 20 to 30 times (Article 24). Late lump-sum payments carry a 1% surcharge for every three days late (Tax Collection Act, Article 20). After 30 days the case goes to enforcement, with a fine of 1 to 5 times the overdue tax depending on the circumstances (Article 23, paragraph 2). Voluntary disclosure works. A company that reports and pays the missing tax before any tip-off or investigation escapes the penalty, though interest runs on the tax (Tax Collection Act, Article 48-1).

If the structure of an intercompany contract or the way it was signed leaves the stamp tax position unclear, you can write to Hovering International Law Firm at wei@hoveringlaw.com.tw with the contract type and where each party signed.

Stamped documents must be kept for two years after the rights and obligations under them end (Article 4). A contract whose obligations all end on December 31, 2027 stays on file until December 31, 2029.

Official sources

• Stamp Tax Act (印花稅法, last amended May 15, 2002): Art. 1, Art. 2, Art. 3, Art. 4, Art. 5, Art. 6, Art. 7, Art. 8, Art. 10, Art. 12, Art. 13, Art. 17, Art. 23, Art. 24
• Enforcement Rules of Stamp Tax Act (印花稅法施行細則, last amended February 13, 1979): Art. 5
• Regulations for Lump-Sum Payment of Stamp Tax (印花稅彙總繳納辦法, descriptive translation; last amended August 12, 1988): Art. 5
• Act Governing the Conversion of Currency Units Used in Existing Laws and Regulations into New Taiwan Dollars (announced July 17, 1992): Art. 2
• Tax Collection Act (稅捐稽徵法, last amended December 17, 2021): Art. 20, Art. 48-1
• MOF eTax portal, local tax handbook on stamp tax: Levy of stamp tax (updated August 26, 2026), Tax-saving methods (updated August 26, 2026), Q&A examples (updated April 9, 2026)
• MOF rulings database (財政部各稅法令函釋檢索系統): 台財稅第11750號函, February 9, 1985; 台財稅字第10404573930號令, July 9, 2015
• Taipei City tax office (臺北市稅捐稽徵處) FAQs: electronic contracts (updated February 18, 2022); contracts signed by both parties abroad (updated January 21, 2026)
• Taichung City local tax bureau (臺中市政府地方稅務局): contracts for work signed abroad (updated September 20, 2024)
• Hsinchu City tax bureau (新竹市稅務局): training slides on stamp tax practice (December 2025)

Sources checked: October 6, 2026