Friday, 13 March 2015

Taiwan proposes amendments to transfer pricing guidelines

On 7 January 2015, Taiwan’s Ministry of Finance proposed amendments to the transfer pricing guidelines (No. 10304651710) (Guidelines) and released the draft amendments which was enacted on 4 March 2015. There is one new provision as well as revisions to eight existing provisions. The new provision provides the application of the arm’s length principle in business restructuring. The revisions to the eight existing provisions mainly cover the definition of business restructuring, function and risk analysis of business restructuring, application of the profit split method, pre-filing meeting for an advance pricing arrangement (APA), operating margin on total costs and expenses, and assessment of tax pursuant to the deemed profit method. This Alert summarizes the key features in the proposed amended Guidelines.
Source & more info: EY