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  • How do multinational enterprises submit Master File and CbCR?
    Date:2019-02-26 
    The 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 13th 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) have to submit Master File and CbCR (Country-by-Country Report), which comes into force as of the 2017 Profit-Seeking Enterprise Annual Income Tax Return. Here are the key points as follows:
    1. The rules of 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 has to submit Master File. If there are 2 and more affiliates in Taiwan, it is allowed to appoint one of the affiliates to submit Master File.
      (3)When to submit?
        The Master File should be prepared when filing the Annual Income Tax Return and be submitted to the taxation authority within one year after the end of Fiscal Year.
      (4)How to submit?
        There are two ways to submit Master File: Master File can be submitted along with Annual Income Tax Return from May 1st to June 25th via Internet, or be submitted directly to taxation authority via discs.
    2. The rules of submitting CbCR
      (1)What is the threshold? 
        The consolidated income of the multinational enterprise in the 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)When to submit?
        The CbCR should be submitted to the taxation authority within one year after the end of  Fiscal Year.
      (4)How to submit?
        There are two ways to submit CbCR: CbCR can be submitted along with Annual Income Tax Return in May via Internet, or be submitted directly to taxation authority by media.
        The NTBNA would like to remind enterprises to be aware of whether or not it has reached the threshold of disclosing Master File, CbCR and TP report when filing Profit-Seeking Enterprise Annual Income Tax Return, and to prepare in advance to protect its rights and interests.


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