Taiwan’s Ministry of Finance issued guidance that relaxes the rules requiring a separate analysis for controlled transactions. 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.
