Tax Governance

Tax Governance

D-Link Group adheres to the goal of implementing tax compliance and improving tax risk management.
D-Link Group establishes Group Tax Policy and Management Regulation to implement corporate sustainability development and fulfill social responsibilities. According to D-Link Group’s Group Tax Policy and Management Regulation, the Group takes the Board of Directors as the highest decision maker of effective tax risk management mechanism. In order to put tax management into practice and establish internal tax management mechanism, the company hired tax experts to provide tax education training and tax consulting services to maintain the accuracy of tax compliance.
 
 
D-Link Group is subject to tax laws and regulations in various jurisdictions, in which it operates or conducts business. Any unfavorable changes of tax laws and regulations in these jurisdictions could have an adverse effect on its operating results. Therefore, the company regularly analyzes changes of tax regulations of each jurisdiction, continuously evaluates the local tax laws and regulations, and the recent supervision priorities of the local tax authorities to identify the tax risks arising from jurisdictions. Accounting Division of the Corporate Finance and Operation Center regularly reports the Group tax risk environment, risk assessment and response measures to the top management. Starting from 2023, tax risk management was incorporated into risk management, and reported the status of tax management to the Board of Directors annually.

Tax Governance and Transfer Pricing Policy

  • Compliance Principle
    Commitment to comply with tax regulations in all operating regions and to declare taxes honestly.
  • Risk Control
    Analyze the operational environment and utilize administrative mechanisms to assess tax risks and countermeasures.
  • Reasonable Tax Incentives
    Apply for tax incentives based on commercial reasons and in line with economic substance regulations without using tax havens.
  • Reasonable Structure
    Ensure the enterprise architecture and transaction arrangements are in line with economic substance regulations. No special arrangements shall be used to avoid tax.
  • Information Transparency
    Financial information is disclosed transparently, and tax information is disclosed in accordance with related regulations and standards.
  • Integrity in Communication
    Establish a relationship of mutual respect and honest communication.
  • Arm’s Length Principle for Related-Party Transactions
    In compliance with internationally accepted transfer pricing guidelines announced by the Organization for Economic Cooperation and Development (OECD).

Compliance with Global Transfer Pricing

In response to the international requirements of the three-tiered transfer pricing documentation framework, D-Link Group prepared Master Files and complied with regulatory declaration to enhance the transparency of the tax information of the Group and implement global transfer pricing.
 
D-Link Group’s companies registered in the Cayman Islands and the British Virgin Islands act as holding companies, which are for the purpose of holding shares. If there is any surplus distribution of the reinvestment company hold by the holding company, the holding company will remit such surplus to the ultimate parent company, D-Link Corporation, and pay corresponding income tax in Taiwan.

Country-by-Country Tax Information for 2023 and 2024

Net Revenue

Profit (Loss) Before Tax

Income Tax Expense

Income Tax Paid

Effective Tax Rate

The average adjusted effective tax rate of D-Link Group in the two-year period was 34% and cash tax rate of D-Link Group in the two-year period was 37%,  which were higher than “Technology Hardware & Equipment” group averages (the average effective tax rate 22.5% and the average cash tax rate 24.35%) announced by CSA Handbook, since statutory tax rates of most overseas subsidiaries (such as Italy, France, Spain, India and Japan, etc.) are higher than 24%.

Unit: NTD million



2024

2023

Average


Profit before tax (a)

362

861

612


Reported taxes (b)

230

163

197

Add (Deduct): temporary difference

(19)

44

12

Adjusted reported taxes (e)

211

207

209


Effective tax rate (c)=(b)/(a)

64%

19%

32%

Adjusted effective tax rate

(d)=(e)/(a)

58%

24%

34%


Income tax paid (f)

207

248

228

Cash tax rate (g)=(f)/(a)

57%

29%

37%

Income and Tax in the Respective Tax Jurisdiction in 2024

Unit: NTD million

Tax Jurisdiction

Net RevenueProfit (Loss) before tax

Income tax PAID

(ReFUND)

Income Tax ACCRUED

Number of employees
Taiwan

5,757

-105

18

0

940

India

5,174

533

133

135

0-300

UAE

2,485

11

000-300
Singapore

747

368

3

1

0-300
Russia

1,269

268

36

42

0-300
UK

698

-328

9

0

0-300
Germany

478

4

000-300
Japan

788

26

0

11

0-300
Italy

244

2

0

1

0-300
USA

620

-188

0

0

0-300
France

300

1

0

1

0-300
Canada

103

-67

0

00-300
Australia

202

-68

-2

0

0-300
Spain

242

3

0

1

0-300
Brazil

9

-45

000-300
China

516

-12

3

0

0-300

Korea

33

-19

000-300
Republic of Moldova

1

0

000-300
B.V.I0

303

000-300
Mauritius0

200

6

6

0-300
Sweden

47

1

0

0

0-300
Poland

74

4

0

1

0-300
Chile

0

0

000-300
Netherlands

10

0

000-300
Peru

3

-5

000-300
Lithuania

17

-2

000-300

Hungary

6

0

0

0

0-300

Czech Republic

7

0

0

0

0-300

Malaysia

12

0

0

0

0-300

Philippines

9

0

0

0

0-300

Colombia

4

-1

000-300
Cayman Islands0

0

000-300

Ukraine

3

-2

0

0

0-300

Kazakhstan

2

1

0

0

0-300

Indonesia

0

-4

0

0

0-300

The Group Entities and the Major Business Operation Across Tax Jurisdictions in 2024


Company Name

Tax Jurisdiction

Business Description

D-Link Corporation

Taiwan

R&D, trading of network equipment and wireless communication systems, sales and after-sales service

D-Link Taiwan Investment Co., Ltd.

TaiwanInvestment
D-Link Canada Inc. Canada

Sales and after-sales service

D-Link Systems, Inc. USA

Sales and after-sales service

D-Link Holding Company Ltd. B.V.IInvestment
D-Link (Europe) Ltd. UK

Sales and after-sales service

D-Link ABSweden

Sales and after-sales service

D-Link (Magyarorszag) KftHungary

Sales and after-sales service

D-Link France SARLFrance

Sales and after-sales service

D-Link Polska Sp Z.o.o. Poland

Sales and after-sales service

D-Link Iberia SLSpain

Sales and after-sales service

D-Link s.r.oCzech Republic

Sales and after-sales service

D-Link (Netherlands) BVNetherlands

Sales and after-sales service

D-Link Mediterraneo SRLItaly

Sales and after-sales service

D-Link (Deutschland) GmbHGermany

Sales and after-sales service

D-Link (Holdings) Ltd. UKInvestment
D-Link (UK) Ltd. UKInvestment
OOO D-Link RussiaRussiaAfter-sales services
Success Stone Overseas Corp. B.V.IInvestment
D-Link Holding Mauritius, Inc. MauritiusInvestment
D-Link (India) Ltd. India

Sales and after-sales service

TeamF1 Networks Private Limited

IndiaR&D

D-Link Shiang-Hai (Cayman) Inc.

Cayman IslandsInvestment

D-Link (Shanghai) Co., Ltd.

China

Sales and after-sales service

Netpro (Shanghai) Co., Ltd.

China

R&D and trading

D-Link International Pte. Ltd.Singapore

Sales and after-sales service

D-Link Korea Limited

Korea

Sales and after-sales service

D-Link Trade M S.R.LRepublic of Moldova

Sales and after-sales service

D-Link Capital Investment Co. Ltd.

B.V.IInvestment
D-Link Malaysia Sdn BhdMalaysia

Sales and after-sales service

D-Link Sudamerica SpA

Chile

Sales and after-sales service

D-Link Japan K.K. Japan

Sales and after-sales service

D-Link Australia Pty Ltd. Australia

Sales and after-sales service

D-Link Middle East FZE

UAE

Sales and after-sales service

D-Link Brazil LTDA. Brazil

Sales and after-sales service

D-Link Investment Pte. Ltd.SingaporeInvestment
OOO D-Link TradeRussia

Sales and after-sales service

D-Link Latin-America Company Ltd. Cayman IslandsInvestment
D-Link Peru S.A. Peru

Sales and after-sales service

D-Link de Colombia S.A.S. Colombia

Sales and after-sales service

D-Link Guatemala S.A. Guatemala

Sales and after-sales service

D-Link Service Lithuania, UAB

Lithuania

After-sales services

D-Link Service (Ukraine)

Ukraine

Sales and after-sales service

D-Link Service (Kazakhstan)

Kazakhstan

Sales and after-sales service

Cameo Communications, Inc.

Taiwan

Manufacturing, sales, R&D

Qianjin Investment Co., Ltd.

Taiwan

Investment

Huge Castle Ltd

Samoa

Investment

Perfect Choice Co., Ltd.

Mauritius

Investment and trading

Luis Jo’se Investment Inc.

B.V.I

Investment

Suzhou Soarnex Technology Co., Ltd

China

Software development and software service for computer information systems

PT DLink System Indonesia

Indonesia

Sales and after-sales service