A Taiwanese distributor in the Jat Health Corporation group had deducted amortizations and royalty payments related to distribution rights.
These deductions had been partially denied by the Taiwanese tax administration.
The case was brought to court.
The Supreme Administrative court dismissed the appeal and upheld the assessment.
“The Appellant’s business turnover has increased from $868,217 in FY07 to $1,002,570,293 in FY12, with such a high growth rate, and the Appellant has to bear the increase in business tax, which is not an objective comparative analysis and is not sufficient to conclude that the purchase of the disputed supply rights was necessary or reasonable for the operation of the business.”
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