Taiwan’s Ministry of Finance (MoF) announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting On 11th December 2017.
Transfer pricing guidance issued in November 2017 (and known in English as “Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s Length Transfer Pricing”) generally reflects the requirements under the OECD’s base erosion and profit shifting (BEPS) Action 13 report.
Under this guidance, multinational enterprises (MNEs) that have group members in Taiwan may be required to file a Master file and CbC report, beginning for fiscal year 2017 and later. The safe harbor exemption guidance was issued in late 2017 after considering the compliance costs that MNEs could incur in preparing their transfer pricing documents. That guidance also took into account certain international practices, existing conditions in Taiwan, and public comments and opinions.
A Taiwanese entity will be exempted from filing the Master File if any one of the following conditions is met; either total annual turnover (include operating and non-operating) has not exceeded NTD 3 billion, or total cross-border controlled transaction amount has not exceeded NTD 1.5 billion.
