Taiwan Transfer Pricing Documentation Requirements
Taiwan requires a Master File and Local File from entities above its turnover and transaction thresholds, while exempt entities must still produce substitute documentation. Safe harbour criteria relieve smaller taxpayers from the full transfer pricing report, and penalties for non-compliance can be imposed repeatedly.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Turnover > TWD 3bn and cross-border controlled transactions > TWD 1.5bn | 12 months after fiscal year-end | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | ZH / EN | Yes (TWD 3,000 to TWD 30,000, repeatable) |
Local File Substitute documentation where exempt
Required | Revenue > TWD 300m and related-party transactions > TWD 200m (exemptions to TWD 500m) | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | ZH (EN by prior approval) | Yes (TWD 3,000 to TWD 30,000, repeatable) |
CbC report Required | Group revenue ≥ TWD 27,000m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Taiwan deadline
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Scope of the documentation obligation
A Taiwanese entity is exempt from preparing and submitting the Master File where its total annual turnover does not exceed TWD 3 billion or its total cross-border controlled transactions do not exceed TWD 1.5 billion, although the tax authority retains the right to request a Master File in writing during an audit. The Local File is not required where annual revenue does not exceed TWD 300 million or related-party transactions do not exceed TWD 200 million, with a further conditional exemption available between TWD 300 million and TWD 500 million of revenue. An entity that is not required to prepare a Local File must nonetheless produce substitute documentation supporting its pricing.
Distinctive features of the Taiwanese regime
The defining feature of the Taiwanese regime is that exemption from the Local File does not equate to no documentation. An exempt entity must still hold substitute documentation, which may include records of public bidding or other support for the arm’s length nature of its transactions, so the obligation scales down rather than disappearing. Safe harbour criteria relieve smaller taxpayers from preparing a full transfer pricing report where, for example, total annual revenue does not exceed TWD 300 million. The penalty for failing to comply with a filing request ranges from TWD 3,000 to TWD 30,000 and can be imposed multiple times under the Tax Collection Act.
Benchmarking and comparables
Asia-Pacific regional benchmarks are widely accepted in practice. A multi-year analysis over three years is required. There is no specific requirement for a fresh search every year, but the financials of a benchmarking study must be kept updated to the current year, and where current-year data is not yet available at the filing date the entity may use the most recent three years’ data without the current year. The assessment period is five years where the return was filed within the statutory period and there was no intent to evade by fraud or other improper means.
Frequently asked questions
What is substitute documentation in Taiwan?
An entity exempt from preparing a Local File must still produce substitute documentation supporting the arm's length nature of its transactions, which may include records such as public bidding documentation, rather than holding no documentation at all.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.