Taiwan: Transfer pricing documentation rules - KPMG Global
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Taiwan: Transfer pricing documentation to include country-by-country reporting, Master file

Taiwan: Transfer pricing documentation rules

Taiwan’s Ministry of Finance on 13 November 2017 announced changes to the transfer pricing documentation rules to include documentation recommendations of the OECD under the base erosion and profit shifting (BEPS) Action 13—that is, country-by-country (CbC) reporting and Master file.


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These transfer pricing documentation amendments will apply to fiscal years of 2017 and later. 

Accordingly, the three-tiered transfer pricing documentation will consist of the transfer pricing report (in Taiwan, already implemented effective from 2005), plus the CbC report and the Master file. The compliance thresholds for preparing the CbC reports and Master file have yet to be announced by the Ministry of Finance.


Read a November 2017 report [PDF 258 KB] prepared by the KPMG member firm in Taiwan

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