The Ministry of Finance stated that, the Taiwan-Japan Relations Association and the Japan-Taiwan Exchange Association (hereinafter referred to as the Two Associations) reached a consensus on conducting automatic exchange of Financial Account Information (CRS) in Tax Matters and of Country-by-Country Reports.  The Two Associations also agreed to strictly ensure information security and confidentiality so as to protect the rights of taxpayers.

The Ministry of Finance pointed out that, in the light of the consensus mentioned above, the Ministry of Finance will provide Japan with, as well as receive from Japan, the Financial Account Information (CRS) commencing on or after 2019 and the Country-by-Country Reports of the Ultimate Parent Entity (UPE) of Multinational Enterprise (MNE) Groups of which fiscal year commences on or after January 1, 2017.

The Ministry of Finance further explained that, concerning the Financial Account Information (CRS), the Ministry of Finance will soon make public announcements to include Japan as a “Reportable Jurisdiction” in accordance with Paragraph 2 of Article 25 of the Regulations Governing the Implementation of the Common Standard on Reporting and Due Diligence for Financial Institutions. With respect to the Country-by-Country Reports, the Ministry of Finance has included Japan by releasing the list of Jurisdictions with which the Republic of China (Taiwan) is able to exchange Country-by-Country Reports effectively in accordance with the existing Agreements in force in accordance with Paragraph 7 of Article 22-1 of the Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s-Length Transfer Pricing.  The Ministry of Finance reminded that the Reporting Financial Institutions in Taiwan and the Constituent Entities of Japanese MNE Groups should pay attention to such announcements.

Should inconsistency occur due to translations, the Chinese texts shall prevail.

Contact：Section Chief Mr. Kevin Pao
Telephone：+866-2-2322-8150