Taiwan master file and local file requirements (2026)

What transfer pricing documentation does Taiwan require?

Four deliverables. Disclosure pages filed with the return, a local file kept and produced on request, a master file filed with the local tax office above its threshold, and a country-by-country report above a much larger one. Documents are in Chinese. NTD is the New Taiwan dollar.

The underlying rules sit in Taiwan's transfer pricing assessment regulations^[1], last amended on 28 December 2020.

Who counts as a related party in Taiwan?

Two companies are related when one holds, directly or indirectly, 20% or more of the other's voting shares or capital, or when the same person holds 20% or more of both. The 20% ownership test is the primary trigger.

Ownership is not the only route in. Shared directors, shared executives and other factual control arrangements can create the relationship below the 20% line. Controlled transactions cover goods, services, royalties, financing and cost sharing between related parties.

Do you need a master file in Taiwan?

Only if the Taiwan entity belongs to a multinational group and clears both limbs of the test. The entity is exempt where its full-year net operating plus non-operating revenue is below NTD 3 billion, or where its cross-border controlled transactions are below NTD 1.5 billion. Falling under either figure exempts you.

This is where most summaries go wrong. They flatten the test into a single revenue number. An entity with NTD 4 billion of revenue but only NTD 1 billion of cross-border controlled transactions is still exempt. The two-limb test and the one-year deadline come from a Ministry of Finance ruling of 10 December 2019^[2], which has applied since tax year 2017.

What are Taiwan's local file requirements?

The local file, which Taiwan calls the transfer pricing report, is required from any enterprise with controlled transactions. It must be ready when the annual income tax return is filed, and presented within one month of a written notice, with one extension of up to one month. Smaller taxpayers can substitute other arm's length evidence for the full report.

The tiers come from a Ministry of Finance ruling of 6 November 2008^[3], which the tax database does not mark as superseded. Relief from the full report does not remove the duty to support your pricing with evidence of some kind.

What is Taiwan's country-by-country reporting threshold?

NTD 27 billion of consolidated group revenue in the prior year. A Taiwan ultimate parent above that figure files the report within one year of the fiscal year end. The annual income tax return also discloses which group entities are designated to file the master file and the country-by-country report.

The NTD 27 billion figure is Taiwan's local equivalent of the EUR 750 million standard used elsewhere, not a separate test. The gap that matters is downstream: Taiwan sits outside the automatic exchange network, so where the group cannot deliver the report through exchange, the Taiwan member must file it locally within one month of notice.

What related-party disclosure goes with the Taiwan tax return?

Pages B2 to B6 of the annual profit-seeking enterprise income tax return. They carry the related-party structure chart, the related-party list, the transaction summary and detail, and the group member disclosure. Any enterprise with related parties and controlled transactions files them.

Keep the three timings apart, because this is the recurring point of confusion. The disclosure pages described by the Taipei National Taxation Bureau^[4] are filed with the return by 31 May. The local file is kept and produced only on written notice. The master file and the country-by-country report run on their own one-year deadline.

When are Taiwan's transfer pricing deadlines?

Everything runs off either the 31 May return date or the fiscal year end. The table below maps each obligation against a 31 December year end.

What language must Taiwan transfer pricing documentation be in?

Chinese. A foreign-language document needs a Chinese translation unless the tax authority approves the English version. All thresholds are set in New Taiwan dollars.

For a group that prepares one global master file in English, budget for Traditional Chinese translation in Taiwan and start it early. Approval of an English file is discretionary and local, so it is not something to plan around.

What are the penalties for missing transfer pricing documentation in Taiwan?

A fine of up to twice the tax evaded, charged where the price is at least double or at most half the assessed arm's length price, where the adjustment reaches 10% of income and 3% of net revenue, or where the transfer pricing report is simply not presented. Without a report, the tax office can also assess your income on its own data or on industry profit standards.

The multiplier is confirmed in the Ministry of Finance penalty guidance^[5], updated 27 April 2026. There is no separate fixed fine for failing to prepare a master file. Exposure runs through the adjustment and the understatement route instead.

What is a foreign parent exposed to in Taiwan?

The Taiwan subsidiary files everything, but the parent carries two risks. The Taiwan master file has to stay consistent with the group master file, and a mismatch is the easiest question an auditor can ask. Local filing of the country-by-country report is a live risk rather than a theoretical one, because Taiwan cannot receive the report through the exchange network.

Treat both as owned items at the parent, not as local admin. The Taiwan entity cannot resolve either one on its own.

Can you get an advance pricing agreement in Taiwan?

Yes, unilateral, bilateral and multilateral. The application threshold is NTD 500 million of total transactions or NTD 200 million a year, and an agreement covers three to five years from the application year.

Bilateral and multilateral agreements also need a treaty mutual agreement procedure request to the competent authority. An agreement fixes the method and the range before an audit opens, which is worth more in Taiwan than in most places, because the local file is produced under a one-month clock.

How do Taiwan's rules differ from the OECD baseline?

Taiwan is neither an OECD member nor an Inclusive Framework member, per the OECD Inclusive Framework composition list^[6] updated 28 May 2024. It adopted the three-tier structure of master file, local file and country-by-country report into domestic law anyway. Taiwan is aligned by its own choice, not by treaty obligation.

The practical differences are concrete. Taiwan's regulations do not reference the OECD guidelines, so formal adherence to them is not confirmed. Taiwan has no OECD country profile. There is no safe harbour beyond the documentation exemptions, and a result inside the arm's length range needs no adjustment. The master file test uses two limbs rather than one revenue trigger.

How we help with Taiwan transfer pricing

Taiwan's exposure is consistency and speed: the local master file has to agree with the group one, and the local file has to be in the tax office's hands a month after the letter arrives. We build the benchmarking and the functional analysis, draft the master file and the local file so the two versions match, and keep them current against the 31 May return and the one-year filing dates. See how our transfer pricing software works.

Book a demo to get a Taiwan documentation exposure review before your next return cycle.