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Taiwan's Amended Transfer Pricing Assessment Rules

09 April 2015

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Approved Changes

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Taiwan

Taiwan's Ministry of Finance promulgated amendments to the country's transfer pricing assessment rules on 6 March 2015. The main amendments are summarized below. Business Restructuring Rules are introduced in line with the OECD transfer pricing guidelines in regard to business restructuring. Companies involved in restructuring must now disclose in the annual transfer pricing report whether the restructuring was in compliance with the arm's length principle, and include supporting documentation. In evaluating the arm's length compliance of a restructuring, the following factors should be considered: Special consideration of risk, including: Whether the contractual allocation of risk in the restructuring is consistent...