Taiwan (TW)

Jurisdiction Overview

IDQuestionAnswer
419 *CBCR: Is there a local filing requirement of a global country-by-country reporting file (according to OECD’s BEPS Action 13) by large corporate groups (with a worldwide turnover higher than 750 million Euro) and local subsidiaries of foreign groups? Beyond OECD Legislation: Secondary mechanism is not subject to restrictions imposed by OECD model legislation: any domestic subsidiary of a group would have to file the CbCR in all cases in which the jurisdiction cannot obtain the CbCR via AEoI.
 Data Date: 2019

Notes

 
While Taiwan's legal framework hasn't been reviewed by the OECD, according to KPMG local filing would be required even if there is no international agreement with the parent's jurisdiction. For example, KPMG wrote that local filing will be required if "the UPE has filed a CBCR in its country/jurisdiction of tax residence, but such country/jurisdiction does not have an agreement to exchange CBCR with Taiwan by the CBCR filing deadline in Taiwan. The UPE has filed a CBCR in its country/jurisdiction of tax residence and such country/jurisdiction has an agreement to exchange CBCR with Taiwan, but Taiwan tax authority is unable to effectively obtain the CBCR in accordance with the agreement." (KPMG).

Sources

https://home.kpmg/content/dam/kpmg/us/pdf/2019/11/tnf-beps-action-13-nov7-2019.pdf
 
https://home.kpmg/content/dam/kpmg/tw/pdf/2018/05/tw-etax-alert-issue111-eng.pdf