On 15th Nov. 2019, the Taiwan Ministry of Finance released a new tax ruling (Tai Tsai Shui #10804629000) specifying the requirements to be met, for companies to take into account retroactive transfer pricing (TP) adjustments voluntarily made, when calculating their taxable income. The ruling will be applicable to transactions made from the year 2020.
According to the ruling, among other requirements for voluntary TP adjustments to be taken into account for Taiwan income tax purposes, taxpayers must make corresponding adjustments to their positions regarding other taxes, including customs duty, value added tax and excise tax etc., and must comply with tax withholding requirements where relevant. Furthermore, the ruling provides high level guidelines on the filing of final customs value assessment, which are discussed below.
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