In this article, the author discusses the controlled foreign company legislation recently introduced in Taiwan. The article gives an overview of the main features of the legislation and the Ministry of Finance’s implementation rules. It also addresses double tax relief issues in the context of tiered foreign companies, and the different tax treatment of interests in companies in Mainland China and those in other foreign jurisdictions. The author canvasses the impact on the new rules of the simultaneously introduced place of effective management law, and exchange of information agreements.