On 10 December 2019, the Ministry of Finance (MOF) issued tax ruling no. 10804651540 providing exemption from CbC reporting for Taiwan entities under a MNE Group headquartered outside Taiwan. 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. The new safe harbor rules prescribes that the Taiwan entity will not be required to submit a CbC report if it meets either one of the following:
- 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.
The exemption is applicable for the fiscal year 2017 onwards.
