The Ministry of Finance has simplified the conditions for the application of an advance pricing agreement (APA) and other procedural rules based on the amendments enacted on 6 March 2015. Accordingly, a taxpayer may apply for an APA if the total value of related party transactions amounts to more than TWD 500 million or TWD 200 million per year. The time limit within which the transfer pricing document must be submitted if an application for APA is accepted, has been extended to 3 months from 1 month.
Furthermore, a taxpayer may apply for a per-meeting on APA by providing a simplified transfer pricing document 3 months prior to the end of the tax year in which the related party transactions to be covered by the APA will take place. The simplified transfer pricing document includes the documents on global organizational structure, main business activities, types of related party transactions, analysis of functions, risks, and the reason for the APA application.
