In recent years, some foreign companies have used the loopholes of international tax policies and different tax regulations among various jurisdictions for tax planning, which resulted in tax base erosion and unfair competition for domestic enterprises. In light of this, the Economic Cooperation and Development Organization (OECD) released the Report on "Tax Base Erosion and Profit Transfer" (BEPS) in February 2013 and released the final draft of the 15 Action Plans for the report in October 2015. The BEPS Report and 15 Action Plans provided governments with reference for revising the domestic tax law and the international tax policy, so as to prevent multinational companies deliberately transferring their profits to tax havens or low-tax jurisdictions. The BEPS Report and 15 Action Plans are recognized and supported by the world's twenty largest economic jurisdictions (G20). As a result, anti-tax avoidance has become an important issue for tax authorities in almost every jurisdiction, including the Republic of China (ROC or Taiwan).
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