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, on August 12, 2022, the company invited directors and top managements to participate a tax seminar and hired global tax experts to lecture the impact of the global tax reform on tax governance from the perspective of directors and supervisors. The lecture topics included the global minimum tax rules, Taiwan’s anti-tax avoidance rules and ESG trends on tax governance issues to let directors and top managements understand the changes in international and domestic tax regulations and countermeasures.
 
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. Since 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 2021 and 2022

Net Revenue

Profit (Loss) Before Tax

Income Tax Expense

Income Tax Paid

Effective Tax Rate

The average adjusted effective tax rate and cash tax rate of D-Link Group in the two-year period were both 27%, 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



2022

2021

Average


Profit before tax (a)

458

395

427


Reported taxes (b)

197

77

137

Deduct: temporary difference

56

(8)

24

Adjusted reported taxes (e)

141

85

113


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

43%

19%

32%

Adjusted effective tax rate

(d)=(e)/(a)

31%

22%

27%


Income tax paid (f)

126

101

114

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

28%

25%

27%

Income and Tax in the Respective Tax Jurisdiction in 2022

Unit: NTD million

Tax Jurisdiction

Net RevenueProfit (Loss) before tax

Income tax PAID

(ReFUND)

Income Tax ACCRUED

Number of employees
Taiwan

7,241

137

15

4

515

India

4,323

417

92

104

0-300

UAE

3,472

148

000-300
Singapore

2,491

-137

0

00-300
Russia

1,828

164

3

0

0-300
UK

829

-274

0

0

0-300
Germany

652

10

000-300
Japan

767

25

8

9

0-300
Italy

541

9

5

8

0-300
USA

821

44

-9

0

0-300
France

448

4

3

2

0-300
Canada

300

-133

-4

00-300
Australia

330

13

9

1

0-300
Spain

333

6

1

1

0-300
Brazil

126

-38

000-300
China

1,041

282

000-300
South Korea

63

-6

000-300
Republic of Moldova

1

0000-300
B.V.I0

138

000-300
Mauritius0

156

100-300
Sweden

41

1

100-300
Poland

53

21

1

0-300
Chile

13

1

000-300
Netherlands

14

1000-300
Peru

7

-1

000-300
Lithuania

13

1000-300

Hungary

8

0

0

0

0-300

Czech Republic

9

1

0

0

0-300

Mexico

0

-13

0

0

0-300

Malaysia

12

0

0

0

0-300

Philippines

12

0

0

0

0-300

Colombia

5

0

000-300
Cayman Islands0

282

000-300

The Group Entities and the Major Business Operation
Across Tax Jurisdictions in 2022 were as Follows

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

Yeo-Tai Investment Inc. 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
D-Link Adria d.o.oCroatia

Sales and after-sales service

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

Team F1 Networks Private LimitedIndiaR&D
D-Link Shiang-Hai(Cayman) Inc. Cayman IslandsInvestment

D-Link (Shanghai) Co., Ltd.

China

Sales and after-sales service

Netpro (Shanghai) Co., Ltd.

ChinaR&D
D-Link International Pte. Ltd.Singapore

Sales and after-sales service

D-Link Korea Limited

South Korea

Sales and after-sales service

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

Sales and after-sales service

D-Link Russia Investment Co. Ltd.

B.V.IInvestment
D-Link Malaysia Sdn BhdMalaysia

Sales and after-sales service

D-Link Sudamerica S.A. Chile

Sales and after-sales service

D-Link Mexicana S.A de C.VMexico

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 FZCOUAE

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 Argentina S.A. Argentina

Sales and after-sales service

D-Link Service Lithuania, UABLithuaniaAfter-sales services