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
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