為因應國際移轉訂價發展趨勢及符合國際組織檢視標準，提升課稅資訊透明度，有效防杜跨國避稅，我國參酌OECD BEPS行動計畫13最終報告及建議，於106年11月13日修正營利事業所得稅不合常規移轉訂價查核準則，增訂跨國企業應製作「集團主檔報告(Master File)」及「國別報告(Country-by-Country Report)」，完備國際要求之移轉訂價三層文據架構。
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.
*This event will be conducted in Mandarin. 本次活動將以中文進行
AmCham Taipei member representatives only (Luncheon included)
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