Tax Governance

Tax Governance

Tax Policy

In response to the international trend in tax governance, the compliance of tax laws and regulations, the realization of sustainable corporate development, the enhancement of shareholder value, and the fulfillment of social responsibilities and tax obligations, Diamond Biofund formed the Tax Governance Policy in October 2024, which has been announced and implemented after approval by the chairman. The Company and subsidiaries included in the consolidated financial statements comply with the above Tax Governance Policy in the course of handling various tax affairs.

Tax Governance Policy

Regulatory Compliance
Fulfill the social responsibility of paying taxes according to the tax laws and regulations of each country of operation.
Information Transparency
Disclose tax information through public channels to ensure information transparency.
Risk Control
Tax-related risks and impacts are assessed for transactions and decisions.
Tax Management
We do not use tax structures that have no commercial substance, nor transfer value created to low tax jurisdictions or tax havens.
Transfer Pricing
Commercial substance principles, arm’s length principles, and tax compliance principles shall comply with the International Transfer Pricing Principles promulgated by the Organization for Economic Co-operation and Development (OECD).
Specialty Cultivation
Education and training are provided to enhance the professional knowledge of tax personnel to assess and respond to changes in tax laws.
Mutual Trust and Communication
Establish a sound communication relationship with the donation and collection authority to communicate tax issues in a timely manner.

Tax Information

100% of the operating revenue, profit (loss) before income tax, and income tax expense of Diamond Biofund in 2024 were generated from operations in Taiwan.

Unit: NTD thousand

Country

Major Business Activity

Number of Employees

Operating Revenue

Profit (Loss) Before Income Tax

Income Tax Paid

Income Tax Expense (Benefit)

Taiwan

Venture Capital Investment

25

(2,228,791)

(2,396,406)

952

121,634

Tax Information for the Two Fiscal Years

As a venture capital company, the Company’s operating revenue primarily consists of gains or losses from the valuation of investment targets, recognized in accordance with IFRS as financial assets measured at fair value through profit or loss. Since such valuation gains or losses are unrealized, they are excluded when calculating taxable income. In the event of the disposal of investment targets during the fiscal year, in accordance with the Income Tax Act, gains or losses from the disposal of foreign investments are subject to a 20% tax rate. For domestic investment targets, since securities transaction income has been exempt from income tax since 2016, the securities transaction income of profit-seeking enterprises is subject to the basic income tax under the Income Basic Tax Act (i.e., the minimum tax system), at a tax rate of 12%.

Unit: NTD thousand

Item

2023

2024

Profit (Loss) before Income Tax (A)

(2,583,823)

(2,396,406)

Income Tax Expense (Benefit) (B)

(412)

121,634

Effective Tax Rate % (C) = (B)/(A)

0.02%

-5.08%

Adjustments (D)

Timing Difference

Tax-Exempt Income

Adjusted Effective Tax Expense (Benefit) (E)=(B)+(D)

(412)

121,634

Adjusted Effective Tax Rate% (E)/(A)

0.02%

-5.08%

Income Tax Paid (F)

82,849

952

Cash Tax Rate (F)/(A)

-3.21%

-0.04%

Note: The above tax information is based on the audited financial statements of Diamond Biofund for 2023 and 2024 as detailed on pages 6 and 30。