Taiwan: Country-by-country reporting requirements - KPMG Global
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Taiwan: Country-by-country reporting requirements in draft transfer pricing documentation rules

Taiwan: Country-by-country reporting requirements

The Ministry of Finance issued draft amendments to the regulations under the transfer pricing rules—specifically to provide for the three-tier transfer pricing documentation requirements pursuant to the OECD’s base erosion and profit shifting (BEPS) Action 13 for country-by-country reporting.


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It is expected that the amended rules would apply to fiscal years beginning on or after 1 January 2017.  

The main amendments relevant to the three-tier transfer pricing documentation are:

  • New county-by-country (CbC) reporting rules, including the criteria for the reporting entity, the reporting deadline, the definition of constituent entities and contents of the report
  • New Master file rules, include criteria for the reporting entity, the deadline, and the contents of the report
  • New CbC reporting disclosure requirement on information about the “ultimate parent entity” of a multinational enterprise and the “surrogate parent entity” that files the CbC report 
  • Amended requirements of the contents of Taiwan transfer pricing reporting rules to reflect the recommendations made under BEPS Action 13 report for Local file


Read a 2017 report prepared by the KPMG member firm in Taiwan

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