My Taiwan company has two nominal employees and no real business — will the renewal audit catch it?
Almost certainly yes. Taiwan's investment-immigration renewal review checks whether your company has genuinely operated for three years — labor and health insurance enrollment records, issued invoices, and bank statements are all on the checklist. Two "nominal" employees with no real business activity is exactly the pattern the review is designed to catch, and a rejected renewal means your residence right lapses.
What the renewal review actually checks
When you renew, the Investment Commission (投审会) doesn't just look at whether the company still exists. It examines whether the business has substantively operated. The standard verification package includes:
| Check item | What they look at |
|---|---|
| Employee insurance records | Labor insurance (勞保) and national health insurance (健保) enrollment for your staff, plus pension contributions — all CPA-certified |
| Invoices issued | Whether the company has actually issued uniform invoices (統一發票) — zero invoices over three years is a red flag |
| Bank statements | Business account cash flow matching the declared revenue |
| CPA-audited financial statements | Submitted to the Investment Commission by end of June each year |
The employee headcount you report each year must be backed by insurance-bureau records certified by a CPA — you cannot simply declare two names on a form.
How nominal employees get caught
A "nominal" arrangement typically fails on at least one of these: the two employees have no salary records matching the insurance base, no actual work attendance, or the same two names appear as nominal staff for multiple companies. Investigators cross-check insurance records across companies, so one person "employed" by five shell companies stands out immediately.
What happens if the renewal is rejected
If the review finds no substantive operation, the renewal is denied and your residence permit is not extended. You lose the legal basis to stay, and the three years of investment and waiting are wasted. There is no shortcut around this — the rules were tightened precisely because of past abuse.
How to fix it before renewal
If your renewal is coming up and the books are thin: start genuine operations now (real office, real contracts, real invoices), put actual employees on proper insurance, and make sure this year's CPA-audited statements reflect real activity. A thin first year followed by two genuine years is far better than three empty ones.
Frequently asked questions
Can I hire myself as one of the two employees?
Yes, you may employ yourself — but you must additionally hire two Taiwan-national employees on top of that, and all of them need proper labor/health insurance enrollment.
Do part-time employees count?
Part-time is acceptable as long as it complies with labor law: the employer must enroll them in labor and health insurance and contribute to their pensions.
When are the audited statements due?
By the end of June each year, covering the previous year. For example, a company established in May 2024 submits its 2024 audited statements and employee records by the end of June 2025.
Sources
- https://www.globalimmigrate.com/article/taiwan-investment-company-operations
- Taiwan Investment Commission Q&A on operating an investment enterprise (tcbc.com.tw) — 3-year operation counted from establishment and commencement of business; annual CPA-audited statements and insurance records due by end of June