The Ministry of Finance states that in order to implement the Base Erosion and Profits Shifting (BEPS) related measures, Taiwan and Switzerland have confirmed to exchange Country-by-Country (hereinafter referred to as “CbC”) Reports in accordance with Article 25 (Exchange of Information) of the Agreement between the Taipei Cultural and Economic Delegation in Switzerland and the Trade Office of Swiss Industries, Taipei for the Avoidance of Double Taxation with respect to Taxes on Income.
The Ministry of Finance explains that Taiwan will, based on the reciprocal principle, provide Switzerland with the CbC Reports with respect to fiscal years of Multinational Enterprise Groups within jurisdiction commencing on or after January 1, 2019, and vice versa. The Ministry of Finance has also made a public announcement No.10924519481 on November 3, 2020 to list Switzerland as one of the jurisdictions with which Taiwan is able to exchange CbC Reports effectively in accordance with the existing Agreements in force.
The Ministry of Finance notes that Switzerland is the fourth partner to exchange CbC Reports with Taiwan after Japan, New Zealand, and Australia. Through the CbC Reports being exchanged, the compliance cost of a Constituent Entity of a Taiwanese or Swiss Multinational Enterprise Group with respect to its requirement to submit the CbC Report on the Group’s behalf pursuant to domestic regulations will be eliminated. It will also protect Constituent Entities of a Multinational Enterprise Group from exposing the risk that their Transfer Price may be unduly adjusted; therefore, this mechanism will strengthen transparency on information and cross-border cooperation in anti-tax-avoidance and safeguard fairness in taxation.
Public announcement No.10924519481.pdf
Contact person: Mr. Kevin Pao, Section Chief
Contact Number: (02)2322-8150