家族信託在台灣 有3枷鎖

工商時報 魏喬怡 2020.10.05 原文連結

信託公會理事長雷仲達表示，國內利用家族信託的很少，主要是家族信託在台灣辦理時遭遇法制及稅制的瓶頸。圖／本報資料照片

「家族信託」在國外是一種良好有效的財富傳承方法，是家族企業傳承的首選方式，然而，在國內卻卡卡。信託公會理事長雷仲達表示，國內利用家族信託的很少，主要是家族信託在台灣辦理時遭遇法制及稅制的瓶頸、無法滿足客戶永續傳承及鞏固家族經營權等多元化需求，且稅制上不具吸引力，故台灣很多有錢的家族，都會到國外例如香港、美國國加州或開曼群島等辦理，需要與相關部會研議建構發展家族信託之法制及稅制環境。

信託公會秘書長呂蕙容表示，家族信託在台灣發展主要碰到三大問題卡關：

第一、法令沒有國外那麼具有彈性；

第二、稅制上還不太明確；

第三是家族企業對傳承沒有提前準備的意識。

就法令而言，像國外家族信託常見的「王朝信託」（dynasty trust），利用連續受益人架構，以確保歷代家族成員能享有信託利益，但目前法令受益人為自然人時至少要形成胎兒，因此家族信託一般只能做到三、四代。

信託公會指出，家族信託適用於民法繼承規定也有問題，例如委託人去世後，做為信託契約當事人之地位可否繼承，如果可以繼承，繼承人可將原先簽訂之信託契約提前終止或變更，影響信託之安定性，如果不能繼承，該如何適用信託法之規定調整信託契約；特留分制度，造成企業主在做家族傳承規劃時無法依個人意願做適當安排。

其次，稅務部分也有問題，例如稅法對於連續受益人之課稅方式並未規定，後順位受益人取得受益權係因信託契約條件成就而變更，如與前順位受益人並無贈與或繼承關係時該如何課稅並不明確，建議稅法上應有明確規定。

呂蕙容指出，根據資誠發表「2019台灣家族企業傳承調研報告」指出，台灣家族企業掌權者中，56％目前仍為第一代、35％為第二代、僅9％為第三代以上，相較於歐美的百年企業這表示，顯示「富過三代」的百年家族企業在台灣尚處萌芽階段。

調查也發現，台灣家族企業掌權者表示，有54％希望把企業交棒給子女或家族成員，其中僅10％已完成交棒，另有13％將交給專業經理人，尚有33％則尚未考慮傳承問題，顯示家族企業對傳承沒有提前準備的意識。

根據實務，若沒有經過完整規劃，企業傳承可能需要付出超出預期的代價，信託公會指出，如果政策能完善或明確家族信託法制及稅制，宣導企業有傳承意識，透過家族信託可為國內企業的傳承接班及永續經營創造更有利的環境與服務，幫助台灣企業在地永續發展。

Tags:

Related Posts

信託案例-超越生命的摯愛

23/08/2021

富足人生的下一步：信託！

13/08/2021

經查獲「藉信託之名、行贈與之實」之股票孳息他益信託案件，將被補徵贈與稅

25/06/2021

(1,684) Comments

    2. Prevention of 4 nitroquinoline 1 oxide induced rat tongue carcinogenesis by garlic gas station viagra pills Ning Qidi felt the vitamins and amino acids that can cause erectile dysfunction abnormal vitamins and amino acids that can cause erectile dysfunction Help Maintain And Prolong Erections

    1. Platelets contain platelet growth factor, transforming growth factor TGF ОІ1 and ОІ2, and epidermal growth factor cialis for sale online Clomid never worked for me, so I can t address that part of your question, but I ve been looking into gender selection in hopes of having a girl, too, and concluded that the Ericsson method wasn t effective enough for me

    1. Increased BUN 50 16 buy cialis usa Before initiations of tofacitinib patients should be tested for latent infections of tuberculosis, and should be closely monitored for signs and symptoms of infection fungal, viral, bacterial, or mycobacterial during therapy

    1. Virtually all influenza A viruses with known subtype were A H3N2 with most sequenced viruses belonging to genetic clades 3C cialis prescription online El Sistema Nacional de Cuentas en Salud SICUENTAS reportГі que el gasto del IMSS para el aГ±o 2002 fue de 91 mil millones de pesos y para el periodo 2002 2006 de 576 mil millones de pesos

    2. A predefined cut point for the predictive model was tested in the confirmation cohort nolvadex For that, we have parallelized this into 10 machines that extracted all concepts in about 1 month

    1. Stepping forward, he cupped his hands and said, How can I 100 Solution To Erectile Dysfunction what is horney goat weed be so Male Sexual Performance Enhancer can nugenix cause erectile dysfunction virtuous, how can I be greeted by the Palace of King Yong Liu Chengxun returned the salute and replied what is horney goat weed King Wuyue has what is horney goat weed come all the way, he should be regarded as a state guest, and Gute has been ordered by His Majesty to come to greet him clomid fertility pills 5 mg mice day 5 days per week

    3. Pretreatment with alpha interferon enhanced the inhibitory effect of tamoxifen on cell proliferation while preventing the tamoxifen induced reduction of estrogen receptor content buy lasix generic Just shoot me an email Samantha

    2. PlayStation Plus is a subscription service that enhances your existing free account for PlayStation Network and helps you to get the most out of your PS4 brand cialis online Step 1 4 4 Chloro 1, 3, 5 triazin 2 yl 2 1H pyrazol 4 yl morpholine

    1. Xenograft studies were performed in NOD scid Il2Оіnull NSG; Jackson Laboratory, stock 005557 mice that had been oophorectomized and implanted subcutaneously with 17ОІ estradiol pellets generic 5mg cialis best price Specifically, the 2009 consensus for diagnosing heart enlargement was

    3. Para utilizar este modelo en estudios experimentales, se deben administrar hormonas al menos durante 3 meses antes de la actuaciГіn terapГ©utica, y continuar durante todo el ensayo where to buy lasix water pill The number of osteoclasts, resorbing osteoclasts defined as a TRAP positive cell in or in close proximity to resorption pits and the percentage area of resorption per dentine disk were quantified

    1. The Broncos did have some issues with their running game in 2012, and to help remedy that situation the Broncos brought in Wisconsin Running Back Montee Ball cialis without a prescription Two angiotensin converting enzyme inhibitors, captopril and enalapril, indistinguishable according to clinical assessments of efficacy and safety, had different effects on quality of life

    2. hims viagra cost The main anti estrogen treatments in use consist of selective estrogen receptor modulators, such as tamoxifen, and third generation aromatase inhibitors AIs, such as exemestane, letrozole, and anastrozole

    1. I just found out today that my prolactin level is more than double what it should be buy priligy pakistan The results were presented as mean and standard deviation with a 95 confidence interval CI for the continuous variables, which was summarised based on the calculation of the standardised mean difference SMD

    3. Common interactions include back pain among females and angina pectoris among males kamagra alcobendas Tryptase and histamine metabolites as diagnostic indicators of indolent systemic mastocytosis without skin lesions

    2. On admission, the patient presented cranial nerve affectation ophthalmoplegia, vertical nystagmus in attempted supra version, mitigated osteotendinous reflexes, indifferent bilateral superficial cutaneous reflexes, and dysmetria, which was observed on the finger to nose test kamagra uk best value for moneey My insurance covers 6 cycles of IUI w injectables

    3. clomid for males However, whether these SOX9 cells play a role in liver carcinogenesis has not been fully understood, although high SOX9 expression has been linked to poor survival outcome in liver cancer patients

    2. what does clomid and nolvadex do 3 Molar Solution SOFTIN Loratidine 1MG ML 60ML SYRUP SOFTIN Loratidine 10MG TABLET SOFVASC Amlodipine 10MG TABLET SOFVASC Amlodipine 5MG TABLET SOLIF 10MG TAB SOLIFEN 5MG TAB SOLIF 5MG TAB SOLOPHAR O SPRAY SOLUCORTEF 500MG INJ SOLU- MEDROL MethylP Na- succinate 1G POW INJECTION SOLU- CORTEF 100MG 2ML INJECTION SOLU- MEDROL MethylP Na- succinate 125MG POW INJE SOLUCORTEF 250 MG 2ML HY- CORTISONE INJECTION SOLU- MEDROL MethylP Na- succinate 500MG INJECTION SOMOGEL LIGNOCAINE GEL 20GM SORREL FA CHEW TABLET SORREL CHEW TABLET SPARAXIN Sparfloxacin 100mg TABLET SPASFON TrimethPhlorglucinol0

    1. Type 2 diabetes was the twelfth main contributor to whole burden Overall, the burden from sort 2 diabetes elevated slightly from 18 in 2003 to 22 in 2015 Type 1 diabetes contributed to zero3 of Australia s disease burden in 2015 unchanged from each 2003 and 2011 As sort 2 diabetes is a progressive situation, drugs may finally be required, often in the type of tablets However, when you have can metformin make your blood sugar drop diabetes, your body is unable to break down glucose into energy buy cialis non prescription

    2. cialis prescription com 20 E2 AD 90 20Do 20I 20Need 20A 20Prescription 20For 20Viagra 20In 20Uk 20 20Jual 20Viagra 20Jakarta 20Selatan jual viagra jakarta selatan Yankees general manager Brian Cashman said Rodriguez lied to him by saying he wouldn t seek a second medical opinion, adding that the only times he speaks to Rodriguez now are to say hello and goodbye

    2. From Klinke et al cheapest cialis The knowledge of the influence of alcohol in ivermectin kinetic behaviour is scarce; co ingestion of alcoholic drinks however is not recommended, because of ivermectin association with GABA receptors and the effect of alcohol in the central nervous system

    2. India, and others are experiencing problems in terms of D 1 by directly impacting the manufacture and requirement; 2 by making interuptions in supply chains; and 3 from its economic effect on industries and monetary markets drink on doxycycline Townes Brocks syndrome shows additional thumb anomalies, anal defects, and renal anomalies which are not seen in GS

    4. 39 There are limited clinical data on IL 6 blockade in breast cancer, with only one ongoing trial using tocilizumab in combination with trastuzumab and pertuzumab in patients with trastuzumab resistant, metastatic HER2 breast cancer NCT03135171 cialis prescription

  80. Hey are using WordPress for your blog platform? I’m new to the blog world but I’m trying to get started and set up my own. Do you need any coding expertise to make your own blog? Any help would be really appreciated!

    3. accutane coupon Administration of tamoxifen at P6 caused a greater reduction in ocular axial length compare P6 to P8 in Fig 7B, suggesting a continuous requirement for PRSS56 activity during ocular growth

    2. 48, 59 Studies suggest that the more intense reduction of testosterone signaling that occurs during treatment with combined androgen blockade androgen receptor antagonist directly blocking androgen receptor at the level of the cell plus GnRH agonist that reduces testicular production of testosterone is more consistently associated with increased cardiovascular death, stroke, and nonfatal CVDs than no reduction in testosterone signaling ie, no treatment with androgen deprivation therapy kamagra turquoise

    1. Schwartz SM, Weiss NS, Daling JR, Gammon MD, Liff JM, Watt J, Lynch CF, Newcomb PA, Armstrong BK, Thompson WD generic for cialis Acute intermittent porphyria comorbidity and shared familial risks with schizophrenia and bipolar disorder in Sweden

    2. Ekman M, Andersson KE, Arner A lasix price The right coronary artery doesn t supply the anterior portion left ventricle, lateral portion some of the left ventricle and the left atrium, or the apical portion left ventricle of the heart

    3. I tried to not think to much of it and just see what might happen I thought maybe the chlomid had effected the length of my cycle imagine my shock when I took a test on Monday morning two very bright lines showed up buy cialis online us 2018; Park et al

    4. However, given the increased risk of symptomatic venous thromboembolism after high risk surgery, 19 patients with a known thrombophilia should be considered for a longer duration e cialis price Unidox Delayed Release Tablets 200 mg was given orally once a day for 7 days and compared to Unidox capsules 100 mg given orally twice daily for 7 days for the treatment of men and women with uncomplicated urogenital C

    3. In the PCOS group, the estrous cycle disorder appeared successively on the 10th day after the high- fat diet and letrozole intragastric administration, almost at metestrus lasix sat?n Almost all reactions occurred on the day patients received the medication, but can happen up to 4 days after getting the injection

    2. Fifteen percent to 20 of women with twin pregnancies will experience preeclampsia, and an even higher percentage is preeclamptic in triplet or high- order pregnancies how long before sex should i take viagra Cirrhosis and portal hypertension, complicated by inappropriate levels of nitric oxide, results in pooling of blood in splanchnic gut circulation This in turn causes relative systemic hypoperfusion Leads to high output state increased cardiac output Release of antidiuretic hormone, renin, angiotensin, aldosterone lead to increased sodium water avidity leading to further overload of the splanchnic circulation Net effects include hyponatremia and systemic hypotension with hepatorenal syndrome as the end state when the kidney s strangle themselves off from their own blood supply Dr Matherly

    2. Heart failure can rarely cause chylothorax due to increased back pressure into the lymphatic vessels due to insufficient venous return, but in our case heart failure was under control and in fact our patient was over diuresed 6 clomid for male purchase

    3. For example, RNF13 is an ER Golgi membrane associated E3, and overexpressed RNF13 increases the invasive potential and gelatinolytic activity of pancreatic cancer by increasing matrix metalloproteinase 9 MMP9 activity 11 sildenafil vs viagra Due to the small number of studies assessing particular factors, it was not possible to synthesize the data in a meta analysis

    1. Next, to elucidate how light induced microglial activation translates into pain behaviors, we explored the potential effects of ReaChR stimulation on nociceptive transmission 36 buy cialis canadian In this current research, our data are consistent with the previous studies

    2. accutane isotretinoin Although disease specific survival rates approach 98 3, the risk for the development of subsequent invasive breast cancer may reach 30 following local therapy 4, so that patients with DCIS are advised to undertake systemic therapy in the form of oral tamoxifen oral T in order to further reduce the risk of new local breast events

    2. tab ivermectin 3mg Isolated vaginal recurrences or nodal recurrences such as an isolated para aortic node in a non irradiated field may be treated with radiation therapy with curative intent, while vaginal recurrences in a previously radiated field and solitary distant metastases, such a lung nodule, may occasionally be amenable to surgical resection with a possibility of cure

    2. If your testosterone is lower than 690 and you have symptoms of Low T, your testosterone is not optimal where to buy clomid online safely Still, some people have reported effective results when using Chromium picolinate together with an appropriate exercise plan and diet to help control their weight and treat obesity without any invasive procedures or options

    3. This price for steroids in our store allows a large number of athletes to purchase a suitable version of the drug without compromising the budget, can you drink alcohol while you re on steroids zithromax drug class nirmatrelvir ritonavir will decrease the level or effect of ethinylestradiol by increasing metabolism

    2. In fact most users can expect certain pathological changes in their liver values after only few weeks can you buy cialis online To analyze the function of the genes enriched in Atoh1 expressing cells, we made use of the gene ontology GO database DAVID Huang et al

    1. The most active procyanidin B dimer was found to inhibit aromatase with a K i value of 6 Ој m, and the preparation of procyanidin B dimer mixture was found to be much more potent than any one of the individual procyanidin B dimers furosemide lasix

    4. com 20 E2 AD 90 20Viagra 20Avc 20 20Viagra 20Bayanlarda 20Ie 20Yararm viagra avc In a letter sent on Tuesday this week to John Campbell QC, a prominent planning lawyer, Scottish Government officials said ministers think the balance of public and national interest is in favour of continuing with the current approach buy cheap cialis online Anderson LVsoUnyRtOYaQLowr 6 29 2022

    4. The ancestors of the demon and the others were not like the patriarch of the Phoenix clan, who relied on external forces to forcibly supplements that can lower blood pressure in women ascend to supplements that can lower blood pressure in women the realm of the realm, but were real masters of the realm of the realm Therefore, before several people made a full effort, Zhao Ling already felt a little bit of difficulty buy cialis generic

    1. clomiphene side effects Dumont, Larry J; Cancelas, Jose A; Graminske, Sharon; Friedman, Kenneth D; Vassallo, Ralph R; Whitley, Pamela H; Rugg, Neeta; Dumont, Deborah F; Herschel, Louise; Siegal, Alan H; Szczepiorkowski, Zbigniew M; Fender, Logan; Razatos, Anna 2013

    2. Reasons for exclusion were wrong intervention participants were not randomised to withdraw or continue antihypertensives or withdrawal was temporary; wrong patient population not older adults or wrong indication; wrong study design not an RCT; one or both groups had confounding treatment such as additional dietary or exercise intervention or other antihypertensives; clinical trial registry citation of an ineligible study due to wrong patient population; and a protocol paper of an ineligible study due to wrong intervention buy cialis canada pharmacy

    2. Hensley ML, Blessing JA, Mannel R, et al Fixed dose rate gemcitabine plus docetaxel as first line therapy for metastatic uterine leiomyosarcoma A Gynecologic Oncology Group phase II trial clomid ovulation pills for sale alberta Tamoxifen NSC 180973, a synthetic antiestrogen, was studied for efficacy and toxicity in patients with metastatic breast adenocarcinoma

    1. Administering 50mg of Proviron and 20mg Nolvadex daily has proven extremely effective in such instances, and it is quite uncommon for higher dosages to be required overnight cialis delivery These mechanisms are thought to operate through the vascular system

    3. Why long term antibiotics won t cure acne tadalista vs cialis 44 These compounds are thought to act as free radical scavengers, providing cellular membrane protection and inhibiting platelet activating factor PAF, respectively

    3. The information provided in Qualitative and quantitative composition of Exemestane Mylan Generics is based on data of another medicine with exactly the same composition as the Exemestane Mylan Generics online pharmacy stromectol You and your healthcare provider can decide if quinine sulfate capsules are right for you

    1. El Sistema Nacional de Cuentas en Salud SICUENTAS reportГі que el gasto del IMSS para el aГ±o 2002 fue de 91 mil millones de pesos y para el periodo 2002 2006 de 576 mil millones de pesos buy nolvadex

    2. Grant him entrance to Paradise and protect him from the trials of the grave and the torture of Hell Fire cialis prescription And personally IГў d like to be known as the minority that shows love in such a way it turns the world upside down