Ms. Cheli Liaw
Qualifications:
-Bachelor of Law, National Taiwan University, Taiwan
-Master of Accounting, George Washington University, USA
-Certified Public Accountant, Taiwan
-Certified Public Accountant, U.S.A
-Enrolled Patent Attorney-in-fact
Other Positions:
-Co-Chair of the Tax Committee of AmCham Taiwan
-Director of the Corporate Operating and Substantiable Development Association
-Associate Professor of National Chun Chi University
-Board member of the Deloitte Taiwan firm
Experience:
2024 - 2026: Cheli served as the Deloitte Financial Service Industry(FSI) and Private Equity (PE) tax leader in Asia Pacific(AP) since 2024. Prior to taking the AP roles, she was leading International Tax. M&A Tax and Deloitte Private in Deloitte Taiwan. Cheli was also the Chief Tax Officer and Tax Policy Leader of Deloitte Taiwan.
Cheli has over 20 years of experience in providing international tax & M&A tax services. Cheli has extensive experience in cross-border merger and acquisition transactions as well as restructuring projects. The other relevant experiences are listed below. . Cheli has been selected as Women in Tax Leader and Highly Regarded Practitioner of International Tax Review for many years including 2025.
-Provided general tax advice to a Taiwan leading semiconductor assembling and testing service provider. The services include, but not limited to Taiwan corporate income tax(CIT) , transfer pricing issues, the review of various technology transfer agreements, Pillar 2 consultation and outbound investment.
-Assisted a Taiwan based technology company to dispose its Chinese subsidiaries. Our work include vender TDD and analyzed different exit scenarios.
-Assisted US based technology multinational company(MNC) in preparing for its Taiwan CIT tax audit by developing tax audit strategy and validate the technical grounds for tax appeal.
-Assisted US based cloud computing MNC for its transfer pricing audit in Taiwan and analyzed the comparable used and develop audit strategy. Furthermore, We also applied for the relevant tax reliefs such as business profit exemptions or deemed profit method to mitigate the tax burden in Taiwan.
-Assisted US based e-commerce group in preparing their CIT and VAT returns, treaty benefit applications and various tax reliefs under the domestic tax laws.
-Provided general tax advice to Korean #1 e-commence company for its Taiwan business including, but not limited to Taiwan corporate income tax(CIT) , transfer pricing, VAT and customs issues.
-Assisted a Taiwan based technology company to acquire a group of EU entities. Our work includes TDD, acquisition structuring analysis and SPA review.
-Provided tax analysis/consultation for the first foreign commercial bank and security house for their domestication in Taiwan.
-Helped many FSIs for their Taiwan tax issues including tax treaty applications, tax reclaims, underwriting tax issues and transferring pricing tax audits. Cheli used to advise and assist the US & European based brokerage firms in handling their transfer pricing tax audits with the global profit split method. Cheli helped to resolve the issues including the withholding tax, CIT and business tax from the downward adjustments which led to a satisfactory settlement for the clients.
-Advised the Australian based financial investor in its investment in the first wind farm projects and other renewable projects in Taiwan. Our work includes TDD, the advice on the acquisition and funding structures, cash repatriation strategy, financial model review and exit strategy;
-Provided advice to the European based energy company in its wind farm projects in Taiwan during different stages . Our works include the tax advice on the investment and funding structure, the analysis during the development stage as well as the indirect tax analysis on the goods and equipment imported; Currently, we are conducting vender TDD, review of ax assumption of the financial model, tax information memorandum preparation transaction support and SPA review.
-Advised on the US based private equity fund for its acquisition of green energy project including the acquisition structure, TDD, SPA review and cash repatriation strategy; and
-Advised on the European based investor on its acquisition of solar projects in Taiwan including the acquisition structure, model review and transfer pricing analysis.
-Provided the Pillar 2 consultation services to various Taiwan based MNCs including the Technology companies. Our works include to hold the workshop with the clients’ workforce, perform the data analysis, CbcR safe harbour test, and start preparation of the GIR; and
-Provide the audit support regarding GloBe tax provision to the audit team for the firm’s audit clients. Our work include the gathering the relevant information and financial, review the CbcR safe harbour test and review the GloBe tax provision calculation.
Other Relevant Experiences:
-Had one year experience working in accounting department of a Taiwan listing company (Walsin Group) to assist the day-to- day accounting operation, including working with external audit team for the preparation of the financial statement and CIT returns, participating in the SAP rollout and involving in various group restructuring projects;
-Led the international & M&A tax practice in Deloitte Taiwan to supervise 80+ international tax &M&A team members, prepare the business plan, meet financial goal, and work with various BU other Deloitte offices and alliance firms to discuss the cooperation and explore the firm’s business opportunity;
-Led the Deloitte AP FSI and PE Tax team to identify the key business offerings, supervise the key priority accounts, meet the financial goals, organize the marketing events, and report to the Global FSI Tax Leader, AP FSI leader and AP Tax & Legal Tax leader;
-As the Deloitte Taiwan’s Chief Tax Officer, Cheli helped the review of the firms’ CIT return, resolved the inter-firms’ tax issues, assessed the permanent establishment(PE) issues and applied the various tax reliefs for the firm;
-As the Tax Policy Leader, Cheli needed to understand the most recent draft tax bills and associated tax impact in Taiwan as well as the various tax developments within the countries of Asia Pacific.
-As a Co-chair of the Tax Committee of AmCham Taiwan, Cheli drafted and prepared the white paper for various tax issues to lobby to the Taiwan government to either issue the new tax bills or rulings or improve the tax administration efficiency in Taiwan market;