我國移轉訂價三層文據架構及應用

AmCham Taipei Tax Committee held a seminar on May 29 at The Sherwood Taipei, featuring Deputy Director-General Hsiu-Ling Sung of the Taxation Administration of the Ministry of Finance, as the speaker.

我國移轉訂價三層文據架構及應用 – this event was conducted in Mandarin.

In response to the international transfer pricing trends of enhancing transparency of tax information and preventing cross-border tax avoidance as well as in line with review standards of international organizations, Taiwan amended its “Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s-Length Transfer Pricing” on November 13, 2017 to incorporate the preparation of Master File and Country-by-Country Report by MNEs with reference to the final reports and recommendations of BEPS Action Plan 13 to accomplish the international requirements for three-tiered transfer pricing documentation.

Furthermore, in order to reduce the compliance cost of multinational enterprise groups in the preparation of transfer pricing documentation, we released the standards of safe harbor for exemption from the submission of a master file and country-by-country report on December 13, 2017, taking into account international practices, our situations, and public views. In the case of a profit-seeking enterprise that does not meet the relevant safe harbor standards, it shall disclose the information of related party transactions and multinational enterprise group as well as prepare local file and transfer pricing report when filing income tax returns, and then submit a country-by-country report before the end of 2018.

When: May 29, 2017 (12 PM – 2 PM)

Where: The Sherwood Taipei

Speaker: 宋秀玲 財政部賦稅署副署長
Hsiu-Ling Sung, Deputy Director-General, Taxation Administration, Ministry of Finance

From left to right: AmCham Tax Committee Co-Chair Cheli Liaw, Partner, Deloitte & Touche; Deputy Director-General, Hsiu-Ling Sung Taxation Administration, Ministry of Finance; AmCham Tax Committee Co-Chair Josephine Peng, Senior Counselor, Lee and Li, Attorneys-at-Law; AmCham Tax Committee Co-Chair Stella Lai, Public Affairs Consultant, Government Affairs Consultant, Dell (Taiwan) B.V. Taiwan Branch

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