A TP report should include the following contents: background information and industry overview, functional and risk analysis of all transacting parties, evaluation of each controlled transaction based on prescribed rules, selection of comparable parties based on certain criteria, analysis of degrees of comparability, selection of the most appropriate method, disclosure of pricing strategy and other relevant information regarding other participants in the controlled transactions, and determination of whether the controlled transactions are within arm’s length range.
International tax systems continues to evolve, aiming to tackle concerns over base erosion and profit shifting (BEPS) and perceived international tax avoidance techniques performed by high-profile multinationals. The OECD’s Action Plan and recommendations on BEPS have greatly influenced how Taiwan intends to shape its transfer pricing regime.
Article 1 of the Value Added and Non-Value Added Business Tax Act states
In addition to the Transfer Pricing Audit Regulations,the following two tax rulings play an important role in transfer pricing practice in Taiwan.