Dziś jest środa, 4th Sierpień 2021

Taiwan Cbcr Exchange Agreement

Although not explicitly stated, Taiwan appears to follow the LOCAL OECD guidelines of December 2017 (pre-registration) on the basis of the list of jurisdictions. These guidelines provide that the second general condition for local secondary notification, without a CBC exchange agreement, does not include circumstances in which no international agreement is in effect (TIEA, tax contract, mutual assistance agreement). The legal systems listed by Taiwan all have an international agreement in place, so that the local notification requirement, which is not based on any cbC exchange, can be applied in accordance with OECD guidelines. Taiwan`s Ministry of Finance issued a notice containing a list of legal systems with which Taiwan has an information exchange agreement, but not for the exchange of country reports (CBC). In general, Taiwanese companies belonging to MNE groups are required to submit cbC reports on the spot in Taiwan, with surrogate parent parent companies established in the countries cited, if the group meets the bid requirements, including compliance with a TWD 27 billion threshold of consolidated group revenues in the previous year (nearly 750 million euros). The communication of April 27, 2018 indicates that this section outlines all the bilateral exchange relations that currently exist for the automatic exchange of CBC reports between tax authorities. In addition to the legal systems with which the cbC exchange is not yet effective, the communication also specifies that Taiwan is able to exchange cbC relationships with New Zealand and that local notification for constituent companies with a New Zealand parent company will not be necessary, except in the event of an exchange error. In the event of an exchange error, the constituent unit has one month to file the cbC report after registration. According to tax notice 10724507300 of the Taiwanese Ministry of Finance („MOF”) of April 27, 2018, only New Zealand can now exchange DIECR CBCR with Taiwan. The taxpayer must first determine how the Taiwanese company must disclose the relevant information when required to submit the CBCR.

If necessary, only one should consider how the CBCR should be filed. Since taiwan`s MOF can update the list of countries to allow for an irregularly effective cbcr exchange mechanism, it is recommended that Taiwanese companies in foreign MNE groups be advised by their tax advisors to complete TP disclosure forms back in 2017 and to monitor the evolution of the list of contracting countries after the SUBMISSION of the CIT. In August 2020, more than 2,500 bilateral exchanges were activated for jurisdictions that committed to exchange CBC reports, and the first automatic exchange of CBC reports took place in June 2018. These include exchanges between the 88 signatory states of the EU Competent Authority Convention, the CNC, between EU member states under the 2016/881/EU Directive and between signatories to bilateral agreements to exchange exchange agreements of competent authorities under double taxation agreements or exchange of tax information, including 41 bilateral agreements with the United States. Legal systems continue to negotiate CBC reporting agreements and the OECD will issue regular updates to clarify things for MNE groups and tax administrations. This page is regularly updated as other jurisdictions activate their bilateral relations. Taiwan will continue to actively negotiate the exchange of cbC relationships with publicly traded jurisdictions and will provide updates to the list. The number in brackets behind each jurisdiction in the drop-down menu indicates the total number of bilateral exchange relations currently activated in relation to that jurisdiction. If, for a given jurisdiction, the number of trading partners on the list as CBC reports is greater than the number of stock exchange partners designated as recipients of the jurisdiction`s cbC reports, this may be explained by the fact that a number of these trading partners have „non-reciprocal jurisdictions” (i.e..

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