I’m certainly not an employee of any firm or company and do not collect a salary.
Look, not sure why I’m arguing with you about this as you don’t work for the tax man.
What I’m doing has their red stamp of approval and many others do the same thing for all kinds of income including trusts. I’d encourage others to explore this structure. It takes some paperwork, but accountants will be familiar with it.
I’ll argue it though, for posterity.
So let’s take several situations. I’ll use variants on an example, for sake of clarity:
Situation 1:
Person is a successful blogger and writes a blog post while in Taiwan (let’s say not about taiwan). They start earning money instantly from whatever revenue (let’s say ads) which are paid out from a company not in Taiwan. Visitors may or may not be Taiwanese, but it is not targeted to them. (Can’t control who visits your website ultimately, unless you block by geolocation which can be inaccurate and then further block based on billing address and geolocation at checkout if selling something)
The person performed the service in Taiwan, for nobody in Taiwan, and was paid by a company not in Taiwan, and the money was not remitted to Taiwan - only at best, withdrawn at an ATM to spend.
Pay tax?
Situation 2:
Same as situation 1, except person is not a successful blogger. They blog a lot while in Taiwan (not about Taiwan), and they later make it to a point where they are earning revenue, but are no longer in Taiwan when they start making the money from blog posts they wrote while in Taiwan. Everything else is the same (foreign ad/whatever company, etc.)
Pay tax?
Situation 3:
Person already has successful blog (like in situation 1) and is earning an income, but unlike situation 1, they do no work on it while here. Everything else is the same as in situation 1.
Pay tax?
Situation 4:
Person works for a foreign company, comes to Taiwan specifically to write a blog post for a Taiwanese client. (imagining for some reason you need to be in the same room as the client to write a blog post for them)
Pay tax?
Situation 5:
Same as situation 4, except visiting Taiwan incidentally - i.e. they are still employed by a foreign company who has a Taiwanese client they work with/for, but they were paying them for that work (and working with the client) before they entered Taiwan, and their entry doesn’t change anything about that scope of work or the activity or type of activity itself. They don’t even see the client, or communicate any more/differently than otherwise.
Pay tax?
If you read Chinese, this regulation might explain.
所得稅法第八條規定中華民國來源所得認定原則
https://law-out.mof.gov.tw/LawContent.aspx?id=FL050237#:~:text=情形之一者，外國,及協助該項業務。
One might even argue that some foreigners make Taiwan their home because of the AMT 
It might be worth noting that that stamp is not final until the return has been audited, or five years has passed (seven for businesses).
In my experience it’s a fairly well understood norm across many jurisdictions that personal income tax for salaried work is based on personal physical presence when the work was done. There are exceptions, such as where physical presence is less than a certain number of days in a year (for Taiwan, 90), but the more unique of these often require bespoke declarations from the tax authorities. It’s also worth checking any tax treaties between your country and Taiwan.
It turns out this principle is also found outside of income tax. For example, some large companies have a policy that employees transiting through California are not allowed to open their laptops. This is to avoid triggering a state sales tax burden for that company.
Missing the mark here.
Using a corporation to shelter income tax via dividend payouts is very, very, very common. Even if you are in, I dunno, the US/UK/Canada dividends are taxed lower so its a common scheme. It just happens that when the dividends are sent back to Taiwan, the AMT law kicks in.
Not when they are sent here, but rather when you become a tax resident here. Whether the dividends are sent to your accounts in the US, EU, or anywhere else is irrelevant.
Sure that’s my meaning.
But my broader point is, with the right structuring that anyone can do with a modicum of effort, it’s very possible for you to use AMT/overseas income to significantly reduce your tax bill. Everyone seems to be in a tizzy about this, a bit ironically since in the same breath they would defend their landlord not giving them an official receipt for their rent.
From what I read in this thread, it sounds like people are concerned that de-facto salary income being structured as dividends might constitute tax evasion, not avoidance. I am no tax lawyer and not sure if that is legal, but I understand the objections. If you didn’t perform any work and only received dividends, it would be a different story.
It’s a good thing that they aren’t accountants. Nobody seems to understand how contractors structure their business. Nor do they understand why an AMT exists and who it benefits.
Careful with your pronouns there, mate. 
What about the following scenario:
=> Income from the sale of a company is considered as what? Is ATM applicable here? Especially when most “work” was done before moving to Taiwan.
it may be overseas income from transaction. iiuc
The Directions for the Filing and Investigation of Income Derived from Sources(PDF File)
The Income basic tax levied on individual overseas income－Q&A (Simple version)(PDF File)
Starting from this year, there are also CFC rules to consider:
In the case of capital gains earned from selling shares in a CFC, taxable income shall be computed as per below.
Taxable capital gains = Selling price - cost of the shares - residual CFC income already reported * percentage of disposal .
Please note that CFC income for an individual is subject to AMT (Alternative Income Tax) computation.
Readind the definition of CFC I don’t think it applies to me:
You probably are a “Taiwan individual” when you’re a tax resident in Taiwan.
Maybe that could be an argument that those profits aren’t to be taxed in Taiwan when the relevant regulation explicitly excludes high-tax countries.
yeah that might be true.
I first have to figure out what my german tax attorney tells me about paying tax in germany for the sale. If it is none and according to him it should be all taxed in taiwan then I proceed to get into details for the taiwan tax regulation about this matter. I don’t mind to get a tax attorney, if he can help me save thousands. But first maybe go to the tax office 