The National Taxation Bureau of Taipei, Ministry of Finance, stated that profit-seeking enterprises undertaking controlled transactions in 2024 shall prepare a transfer pricing report when filing their 2024 profit-seeking enterprise income tax return in accordance with Paragraph 1, Article 22 of the Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's-Length Transfer Pricing (hereinafter referred to as “the Regulations”). However, enterprises that meet any of the specified conditions may substitute the transfer pricing report with other documentation sufficient to demonstrate that their transfer pricing results are at an arm's-length results in accordance with Paragraph 3, Article 22 of the Regulations; and Point 1 of Ministry of Finance Orders Tai-Tsai-Shui-Zi No. 09704555160,  No. 10304578300, and No. 10800035640, issued on November 6, 2008, February 2, 2015, and September 5, 2019, respectively.

1. The aggregate of operating and non-operating income for the year (hereinafter referred to as “total amount of revenue”) is less than NTD 300,000,000.
2. The total amount of revenue for the year is no less than NTD 300,000,000 but less than NTD 500,000,000, and the profit-seeking enterprise satisfies the following conditions:

   (1) The profit-seeking enterprise is not entitled to any tax incentives, or the aggregate amount of actual tax deductions declared in accordance with any applicable acts from the amount of income tax payable for the current year's income tax return and the additional tax on undistributed earnings from the previous year is no more than NTD 2,000,000.

   (2) The profit-seeking enterprise has not claimed deductions of losses incurred in the previous 10 years, or the total amount of such deductions claimed is no more than NTD 8,000,000.

   (3) Financial holding companies or companies and their subsidiaries specified in the Business Mergers and Acquisitions Act have not engaged in transactions with offshore related parties (including head offices and branch offices); profit-seeking enterprises other than aforementioned companies have not engaged in transactions with offshore affiliated enterprises (including head offices and branch offices).

3. Those who do not meet the above conditions but whose total amount of controlled transactions for the entire year is less than NTD 200 million.

The Bureau explained that profit-seeking enterprises required to prepare a transfer pricing report shall submit the report within one month after receipt of a notice of investigation sent by the tax authority. This deadline may be extended by one additional month if necessary. In addition, to assist profit-seeking enterprises in preparing transfer pricing reports for their controlled transactions in accordance with the Regulations, key points are summarized in the following table to remind taxpayers.

The Bureau urges profit-seeking enterprises to pay attention to the relevant regulations when conducting transfer pricing analysis and to submit the transfer pricing report or other substitute document by the deadline. If there are any questions, taxpayers are welcome to call the toll-free number 0800-000-321.

(Contact person: Section Head Lin from the Profit-Seeking Enterprise Income Tax Division, Tel: 2311-3711 Ext. 1365)