Business Restructuring Amendments to Transfer Pricing Assessment Rules and New APA Procedure

Journal
Taiwan
International Transfer Pricing Journal 2015 (Volume 22), No. 5
The Ministry of Finance has issued new rules regarding contemporaneous transfer pricing documentation, as well as preparation meetings that are part of the APA application process. The Ministry also recently released a tax order that provides an objective formula for calculating a “contribution rate” used to calculate taxable income of non-resident enterprises to reduce the tax liability when only limited functions and risks are carried out in Taiwan.