Taiwanese enterprises must submit Master Files and CbC reports to comply with transfer pricing rules.
The Taiwan’s Ministry of Finance (MoF) reminded profit-seeking enterprises that the deadline for submitting Master Files and Country-by-Country (CbC) reports for the fiscal year 2024 is 31 December 2025.
This announcement was made on 28 November 2025.
The requirement, introduced under the 2017 amendment to the Regulations Governing the Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s-Length Transfer Pricing, mandates three-tiered transfer pricing documentation. Articles 21-1 and 22-1 specify that qualifying enterprises must prepare and submit Master Files and CbC reports within one year after the fiscal year-end. For calendar-year taxpayers, this means 2024 reports are due by the end of 2025.
The MoF warned that failure to submit the documentation may result in fines ranging from TWD 3,000 to TWD 30,000 under Article 46 of the Tax Collection Act and could trigger further risk assessments or transfer pricing examinations.
