National Taxation Bureau of the Northern Area (NTBNA), Ministry of Finance, indicates that due to the trend of developing global transfer pricing mechanism and improving tax information transparency, on November 13, 2017, the Ministry of Finance amended part of the Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s Length Transfer Pricing, in which it is announced that the multinational enterprises’ affiliates in Taiwan (including UPE, ultimate parent entity) are required to file Master File and CbCR (Country-by-Country Report). The amendment comes into force for the profit-seeking enterprise annual income tax returns starting from fiscal year 2017. 
       If the multinational enterprises’ affiliates meet the following conditions, please submit 2018 Master File or CbCR before December 31, 2019.
1. The rules for submitting Master File
(1) What is the threshold? 
   The profit-seeking enterprise’s net operating and non-operating revenue reaches 3 billion NTD and above, and its cross-border controlled transactions over the year reaches 1.5 billion NTD and above.
(2) Who should submit?
    The profit-seeking enterprise in Taiwan which is an affiliate of the multinational enterprise is required to submit Master File. If there are two and more affiliates in Taiwan, one of the affiliates may be appointed to submitted Master File.
(3) How to submit?
     1. Internet filing: Please go to the link (https://tax.nat.gov.tw) of e-Filing and Tax Payment Service of the Ministry of Finance, download and install the e-filing system for Master File and CbCR. Upon successfully uploading Master File and the scanned cover with an affixed official seal, the submission is complete.
    2. Paper or CD-ROM filing: Please submit Master File along with the cover affixed with an official seal to the local tax authority.

2. The rules of submitting CbCR
(1) What is the threshold? 
The consolidated income of the multinational enterprise in previous year reaches 27 billion NTD and above.
(2) Who should submit?
i. If UPE is in Taiwan, UPE should submit CbCR.
ii. If UPE is not in Taiwan, UPE or surrogate parent entity should submit CbCR to its tax authority. However, if CbCR could not be obtained through Exchange of Information Mechanism (such as Tax Treaty, information exchange agreement, etc.), the multinational enterprises’ affiliate (or one of the affiliates) in Taiwan should submit CbCR.
(3) How to submit?
Please go to the link (https://tax.nat.gov.tw) of e-Filing and Tax Payment Service of the Ministry of Finance, download and install the e-filing system for Master File and CbCR. There are two ways to submit CbCR: 
    1. Internet filing: File or import the required information (including CbCR and basic information of the reporting entity). After making sure that there are no errors, please upload the scanned cover with an affixed official seal. Upon receiving the acknowledgment mail or notice, the submission is complete. 
    2. Media filing: File or import the required information (including CbCR and basic information of the reporting entity) and convert to CD-ROM format. After making sure that there are no errors, please submit the CD-ROM along with the scanned cover affixed with an official seal to the local tax authority. 
       NTBNA would like to remind enterprises to be aware of whether or not they have met the prescribed threshold to file Master File and CbCR. With the e-filing system available all year around, it will be easier for multinational enterprises’ affiliates to submit Master File and CbCR by using the e-filing system. For more information, please visit NTBNA’s website at https://www.ntbna.gov.tw/ or dial the toll-free number 0800-000321. NTBNA is pleased to provide further consultation services upon inquiry.