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Taiwan Issues Rules on Mutual Agreement Procedures

30 August 2018

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Approved Changes

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Taiwan

Taiwan's Ministry of Finance published a notice on 28 June 2018 that sets out the general rules for mutual agreement procedures (MAP) under Taiwan's tax treaties. The rules are issued in response to the MAP-related outcomes of BEPS Action 14 (Dispute Resolution). Key points include: A resident of either contracting party to a treaty may apply for MAP if the resident considers that they have been subject to taxation in a manner not in accordance with the treaty, including in relation to matters of tax residence, permanent establishments, tax reductions and exemptions, transfer pricing adjustments, elimination of double taxation, etc.;...