The M41D (Chinese: M41D輕型戰車) was an overhaul upgrade of the ROCA's fleet of M41A1/A2 Walker Bulldogs during the 1990s. As a long-time user of M41 tanks, the ROCA previously attempted to reverse-engineer the tank under the name Type 65 with M41A3-equivalent designs. After attempts to import light tanks to replace the fleet of Bulldogs failed and cross-strait relations became increasingly tense, they sought upgrades for the existing fleet of M41s, including a domestic gun with the capability to fire APFSDS, FCS upgrades, and a new engine for easier maintenance. Fifty tanks were upgraded and peacefully served the ROCA for around two decades. A few continue to serve on Kinmen Island after fatal accidents involving the M41A3.

Introduced in Update "Winged Lions" as the most modern variant of the M41 in-game, this Taiwanese upgrade features APFSDS, thermals, and a laser rangefinder, but trades for a less powerful (but more economical) engine. The high gun depression and laser rangefinder, combined with its poor armour and lack of stabiliser, make this tank well-suited for hull-down sniping, and its good reverse speed allows it to quickly retreat if spotted. Compared to its PLA light tank counterpart, the PTL02, the M41D trades a stabiliser and some firepower for superior reverse mobility, a slightly smaller profile, and increased gun depression.