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Taiwan Ministry of Finance Consulting on Amendments to Transfer Pricing Regulations for Intangibles

27 August 2020

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Proposed Changes

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Taiwan

Taiwan's Ministry of Finance has launched a public consultation on amendments to the transfer pricing regulations. The amendments are meant to provide for the implementation of the OECD guidelines developed as part of BEPS Action 8 to 10 to ensure that transfer pricing outcomes are better aligned with value creation. As provided in the consultation document, amendments include the following: The definition of intangible assets will be revised; When the comparable uncontrolled transaction data (including internal and external) and the controlled transaction are highly comparable, a single comparable uncontrolled transaction will be allowed to determine the single most reliable regular...