Under the transfer pricing safe harbor rules (from 2008), a profit-seeking enterprise is required to prepare a transfer pricing report for each controlled transaction if the amount of the transaction meets a threshold amount. However, if the enterprise can prepare other documents sufficient to prove the arm’s length nature of such controlled transactions, and include this in the transfer pricing report, the transaction may be considered at arm’s length and exempt from the separate analysis requirement.
New guidance—Tax Ruling no. 10304578300 (2 February 2015)—amends and relaxes the threshold requirement, thus allowing waiver of the separate analysis requirement for controlled transactions.
This change is effective with respect to income tax returns filed for the 2014 tax year and later.
Read a February 2015 report [PDF 124 KB] prepared by the KPMG member firm in Taiwan: e-Tax Alert
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