Taiwan has adopted the three-tier transfer pricing documentation in its domestic rules. Therefore, Taiwanese entities with an annual consolidated group revenue for 2016 exceeding NTD 27 billion (approximately U.S. $900 million) will be required to disclose whether they will be the filing entities for country-by-country (CbC) reporting purposes, on the transfer pricing disclosure forms that would be filed as part of the 2017 corporate income tax return.
To date, New Zealand is the only country that can effectively exchange CbC reports with Taiwan. A Taiwanese entity with an ultimate parent company or surrogate parent entity not located in New Zealand will have to designate itself (or another multinational enterprise (MNE) member in Taiwan) as the filing entity for the 2017 CbC report.
Because the Taiwan Ministry of Finance may update the list of countries with which there can be an exchange of CbC reports, Taiwanese entities of foreign MNE groups will want to consider any updates on completing and filing their transfer pricing disclosure forms for 2017 with their corporate income tax returns and will want to monitor for any further developments regarding the list of treaty countries after the corporate income tax filing.
Read a May 2018 report [PDF 319 KB] prepared by the KPMG member firm in Taiwan
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.