On 26 February 2019, National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance of Taiwan has published guidance on the submission of the Master file and Country-by-Country report by MNEs. Here are the key points as follows:

The Master file must include:

– The profit-seeking enterprise’s net operating and non-operating revenue which is an affiliate of the multinational enterprise having 3 billion NTD and above, and its cross-border controlled transactions over the year having 1.5 billion NTD and above has to submit Master file. If there are 2 and more affiliates in Taiwan, it is allowed to appoint one of the affiliates to submit Master File and the Master File must be prepared when filing the Annual Income Tax Return and be submitted to the taxation authority within one year after the end of Fiscal Year.

-Master File can be submitted along with Annual Income Tax Return from May 1st to June 25th via Internet, or be submitted directly to taxation authority via discs.

The CbC report must include:

-If ultimate parent entity is in Taiwan or not in Taiwan, UPE or a surrogate parent company should submit CbCR to its tax authority. However, if CbCR cannot be obtained through an information exchange mechanism (for example, a tax treaty, information sharing agreement, etc.), a branch of multinational enterprise’s consolidated income in the previous year reaches 27 billion NTD and above, (or one of the branches) in Taiwan must submit to CbCR.

-The CbCR should be submitted to the taxation authority within one year after the end of Fiscal Year. CbCR can be submitted along with Annual Income Tax Return in May via Internet, or be submitted directly to taxation authority by media.