Taiwan: Safe harbor exemption, Master file | KPMG Global
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Taiwan: Safe harbor exemption, Master file and country-by-country reporting submissions

Taiwan: Safe harbor exemption, Master file

Taiwan's Ministry of Finance in December 2017 announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting.


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Transfer pricing guidance issued in November 2017 (and known in English as “Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s Length Transfer Pricing”) generally reflects the requirements under the OECD’s base erosion and profit shifting (BEPS) Action 13 report. Under this guidance, multinational enterprises (MNEs) that have group members in Taiwan may be required to file a Master file and CbC report, beginning for fiscal year 2017 and later.

The safe harbor exemption guidance was issued in late 2017 after considering the compliance costs that MNEs could incur in preparing their transfer pricing documents. That guidance also took into account certain international practices, existing conditions in Taiwan, and public comments and opinions.


Read a January 2018 report [PDF 300 KB] prepared by the KPMG member firm in Taiwan

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