Executive summary

On 23 December 2025, Taiwan's Ministry of Finance (MOF) issued Tax Ruling No. 11404615670 to promulgate the "Directions for the Levy of Individual Income Tax (IIT) on Individuals who Publish Creative or Informational Content Online" (Influencer IIT Guidelines). These Guidelines stipulate the nature of income classified as income from professional practice, the calculation method for the Domestic Profit Contribution Ratio (DPCR) and the tax payment procedures for influencers who are exempt from business tax registration but earn income through publishing creative works or sharing information online.

The Influencer IIT Guidelines govern the levy of IIT on influencers exempt from business tax registration. The "Directions for the Levy of Business Tax on Individuals Who Regularly Publish Creative or Informational Content Online" (Influencer Value-Added Tax (VAT) Guidelines), issued on 10 September 2025, set forth business tax implications, including registration and filing requirements for influencers who are subject to business tax registration and for platforms that utilize influencer content to display advertisements or provide related paid services. (See also EY Global Tax Alert, Taiwanese Government issues 'Directions for the Levy of Business Tax on Individuals who Regularly Publish Creative or Informational Content Online,' dated 3 October 2025.)

Definitions and determination of relevant terms

Domestic influencer refers to an:

• Individual with a residence or domicile in Taiwan
• Individual whose computer equipment or mobile devices are installed in Taiwan
• Individual whose mobile device's phone number area code is 886
• Individual with other relevant information that can qualify him/her as individual in Taiwan (e.g., billing address, IP address, SIM card ID).

Nature of income: When an influencer uploads performance services to a platform and authorizes the platform to use the uploaded content to provide advertising placement services or paid electronic services, the revenue-sharing income the influencer receives from the platform (including advertising revenue share, paid subscription share, live-streaming revenue share, viewer tips or other similar income (influencer income)) is classified as "income from professional practice" under Category 2, Paragraph 1, Article 14 of the Income Tax Act (ITA).

DPCR for Taiwan-sourced income: When an influencer uploads a performance service to a platform and makes it available for viewers to watch, the provision of the service is deemed completed. To assess the transaction flow and the economic connection to Taiwan — i.e., the DPCR (within Taiwan) — and to calculate the influencer's Taiwan-sourced income, the influencer income obtained from the platform shall be determined as follows:

• DPCR is 100% if a domestic influencer uploads performance services to a domestic platform for viewing by domestic or foreign audiences, or uploads to a foreign platform for viewing by domestic audiences.
• DPCR is 50% if (1) a domestic influencer uploads performance services to a foreign platform for viewing by foreign audiences, or (2) a foreign influencer uploads performance services to a domestic platform for viewing by domestic or foreign audiences or uploads to a foreign platform for viewing by domestic audiences.

Taxation principles

If an influencer is an individual residing in Taiwan as defined under the ITA:

• Taiwan sourced income must be filed in an annual IIT return. An influencer's Taiwan-sourced income is calculated by the formula of "Influencer Income multiplied by DPCR." An influencer's taxable Taiwan-sourced income is calculated by deducting either (1) the actual costs supported by accounting records multiplied by DPCR or (2) an influencer's Taiwan-sourced income multiplied by the standard cost/expense ratio released by the MOF (if no accounting records are available).
• Non Taiwan sourced income (the remaining influencer income after excluding Taiwan-sourced income) must be filed in an alternative minimum tax return. An influencer's taxable non Taiwan sourced income is calculated by deducting either the substantiated costs multiplied by (1-DPCR) or the non-Taiwan sourced income multiplied by the standard cost ratio.

If an influencer is an individual not residing in Taiwan:

• Taiwan-sourced income received from a domestic platform: When the domestic platform makes payments to the influencer, the platform must calculate the Taiwan-sourced influencer income based on the DPCR and withhold tax. If the payment amount does not reach the withholding threshold and therefore no tax is withheld, the payment must be reported on a non-withholding tax (non-WHT) statement.
• Taiwan-sourced income received from a foreign platform that has registered in Taiwan: A foreign platform that has completed tax registration pursuant to Article 28-1 of the Taiwan Value-Added and Non-Value-Added Business Tax Act must calculate the Taiwan-sourced influencer income based on the DPCR and withhold tax accordingly, either by withholding the tax itself or by appointing an agent in Taiwan to handle the WHT filing procedures.
• Taiwan-sourced income received from a platform other than the above: The influencer must calculate the Taiwan-sourced influencer income based on the DPCR and file the income tax return by itself or by appointing an agent in Taiwan to handle the tax filing procedures.

Withholding obligations for foreign e-commerce operators

The MOF issued Tax Ruling No. 11404615672 on 23 December 2025 to specify the tax withholding obligation of foreign e-commerce operators who have registered in Taiwan (Registered FECOs). Specifically, a registered FECO is a withholding agent and must withhold taxes pursuant to the ITA for paying income defined in Article 88 of ITA and the other income defined in Article 14 of ITA, by either withholding taxes itself or appointing an agent in Taiwan to handle the WHT filing procedures. In addition, if a foreign platform under Item 3, Subparagraph 2, Paragraph 4 of the Influencer VAT Guidelines provides advertising services to foreign advertisers and the advertisement is viewed by domestic non paying audiences, the advertising service fee shall be considered Taiwan sourced service income and therefore subject to income tax.

Implications

Considering that influencers and platform operators may require time to familiarize themselves with the relevant regulations during the initial implementation stage, the MOF issued No. 11404615671 on 23 December 2025, stipulating that the period from the promulgation of the Influencer IIT Guidelines shall be regarded as a guidance period until 30 June 2026. During this period, if tax withholding, filing or issuance of WHT/non-WHT statements is not carried out as required, the competent tax authority shall actively provide guidance to ensure compliance, and no penalties shall be imposed under the ITA. However, as this is a special provision for the guidance period, influencers and platforms should still consider proactively reporting and paying taxes to the tax authority.

In addition, the Influencer IIT Guidelines govern the classification of income generated from professional practice, the calculation of tax amounts and the tax payment procedures for influencers. However, if influencers earn other types of income not classified as income from professional practice (e.g., income from property transactions), they must still report and pay taxes in accordance with the relevant tax laws.