The National Taxation Bureau of the Southern Area, Ministry of Finance (MOF) indicates that, in order to respond to the global trend of developing anti-tax avoidance and to enhance tax information transparency, domestic profit-seeking enterprises in the territory of the R.O.C. of Multinational Enterprise (MNE) Groups shall prepare Master File and Country-by-Country Report (CbCR) when filing income tax returns, then submit them to the local tax collection authority within one year after the end of the fiscal year from fiscal year 2017.

　　The Bureau further explains that in order to alleviate taxpayers’ compliance cost, the MOF formulated safe harbor rules on December 13th, 2017. To be more precise, a domestic profit-seeking enterprise may be released from the obligation of submitting a Master File or CbCR as long as the following criteria are met:
Master File: A profit-seeking enterprise that is resident in the R.O.C. that is a constituent entity of an MNE Group whose aggregate amount of annual net operating revenue and non-operating revenue is less than NT$3 billion, or total amount of annual cross-border controlled transactions is less than NT$1.5 billion.
Country-by-Country Report:
1.The domestic profit-seeking enterprise is the Ultimate Parent Entity (UPE) of an MNE Group and the annual consolidated group revenue is less than NT$27 billion in the previous year (approximately equivalent to EUR 750 million as of January 2015 as prescribed in BEPS Action 13 Report).
2.Where an MNE Group whose UPE is not resident in the R.O.C., and meets one of the following requirements: 
(1)The UPE of the MNE Group is obligated to file a CbCR in UPE’s jurisdiction of tax residence, and the group is exempt from submitting the CbCR according to the regulations issued in accordance with standards defined in the above-mentioned OECD final report in the jurisdiction of tax residence (which means the total consolidated group revenue is less than EUR 750 million in the previous year).
(2)The UPE of the MNE Group is not obligated to file a CbCR in UPE’s jurisdiction of tax residence and the group has designated one constituent entity to submit the CbCR on behalf of the UPE (hereinafter referred to as the “Surrogate Parent Entity”, or SPE), while the SPE is exempt from submitting the CbCR according to regulations issued in accordance with the standards defined in the above-mentioned OECD final report in the SPE’s jurisdiction of tax residence.
(3)The UPE of the MNE Group is neither obligated to file a CbCR in UPE’s jurisdiction of tax residence nor designate a SPE, and the MNE Group’s total consolidated revenue is less than NT$27 billion in the previous year. 

　　The Bureau reminds such profit-seeking enterprises that don’t meet the aforementioned safe harbor rules should submit the documents to the local tax collection authority via Internet (software can be downloaded from http://tax.nat.gov.tw), by CD-ROM or hard copy within one year after the end of the fiscal year. 

Press Release Statements contact person:
Ms. Chiu, First Examination Division
Tel:06-2223111 ext.8034