close
Share with your friends

e-Tax alert 142 eng- Taiwan Customs Guideline on One-Time Transfer Pricing Adjustments

e-Tax alert 142 eng- Taiwan Customs Guideline on One-Ti

According to Tax Ruling No.10804629000 issued by Taiwan Ministry of Finance (MOF) on November 15, 2019, starting from 2020 fiscal year, when conducting transactions with related parties, a company who meet the requirements is allowed to make one-time TP adjustment before closing the accounting records for the fiscal year.

1000
Ellen Ting

Deputy Head of ASPAC Taiwan Practice, Partner

KPMG in Taiwan

與我聯繫

相關內容

According to Tax Ruling No.10804629000 issued by Taiwan Ministry of Finance (MOF) on November 15, 2019, starting from 2020 fiscal year, when conducting transactions with related parties, a company who meet the requirements is allowed to make one-time TP adjustment before closing the accounting records for the fiscal year. For the above eligibility criteria, please refer to Issue 139 e-Tax alert  published on 2019/11/27.

To assist the companies who have imported goods from related parties and would like to adopt the abovementioned ruling, Taiwan Customs has recently released the “Guidelines on assessing one-time TP adjustment to determine the dutiable value” (the “Guidelines”) on December 31, 2019.

Compliance requirements basically can be distinguished into three phases: 1. upon importation during the year; 2. submitting the One-time TP Adjustment Application and 3. Customs Assessment Process. Based on the information which has been announced so far, in connection with one-time TP adjustment for imported goods’ value assessment, some key points are summarized as follows.

e-taxalert-142eng

KPMG Observations

For the import goods from related parties and needs to make one-time TP adjustment, the requirement procedures stipulated in the Guidelines should be followed. To assist the companies in conducting the adjustment procedures smoothly, KPMG suggests that the companies could conduct a self-assessment step-by-step following with the below flow during the year.

In practical terms, the company may find that the collaboration between departments (e.g. supply chain, logistics, finance, sales team, etc.) would be needed in order to prepare required documents for the one-time TP adjustment application.

Thus, it is recommended that companies should consult with different fields of expertise before applying for the one-time TP adjustment.

 

Authors

Ellen Ting,  Partner
Sylvia Chiang, Manager

© 2020 安侯建業聯合會計師事務所,係與瑞士法律實體 KPMG International Cooperative ("KPMG International") 相關聯的 KPMG 獨立成員機構網路內之成員機構暨中華民國法律下之合夥組織。版權所有,保留一切權利。

上列組織及本文內任何文字不應被解讀或視為上列組織之間有任何母子公司關係,仲介關係,合夥關係,或合營關係。 上述成員機構皆無權限(無論係實際權限,表面權限,默示權限,或任何其他種類之權限)以任何形式約束或使得 KPMG International 或任何上述之成員機構負有任何法律義務。 關於此文內所有資訊皆屬一般通用之性質,且並無意影射任何特定個人或法人之情況。即使我們致力於即時提供精確之資訊,但不保證各位獲得此份資訊時內容準確無誤,亦不保證資訊能精準適用未來之情況。任何人皆不得在未獲得個案專業審視下所產出之專業建議前應用該資訊。

與我們聯繫

 

讓KPMG為您服務

 

loading image 申請服務建議書