Taiwan’s new transfer pricing (TP) guidance encompasses the local file, country-by-country (CbC) report and the Master File, effective for the 2017 tax year.
Inclusion of the TP Master File as a required document to be submitted annually is a new trend, apart from having it available upon audit. Although generally protected by a tax administration’s confidentiality provisions, increasing circulation around the world increases the chances of a leak, inadvertent or otherwise.
Thus, it would be prudent to consider such information as being in the public domain when finalizing this report for distribution.
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