• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 10/24/2013

Taiwan - Tax authorities requesting separate benchmarking analyses during audits 

October 24: Recent reports from Taiwan reveal that during transfer pricing audits, the Taiwanese tax authorities have questioned the appropriateness of adopting an aggregate testing approach in a transfer pricing report and, instead, have requested an additional separate analysis.

The separate analysis requests have been raised at two levels:

  • Separate analysis by transaction type
  • Separate analysis by counterparty

KPMG observation

Tax professionals in Taiwan note that, given this recent audit trend, to avoid having to collect information and perform additional benchmarking analyses in a limited amount of time—or to avoid the risk of not being able to draw an arm’s length conclusion—taxpayers may want to consider (on a case-by-case basis) preparing separate benchmarking analyses by transaction type when preparing their transfer pricing reports.

Read an October 2013 report [PDF 162 KB] prepared by the KPMG member firm in Taiwan: The transfer pricing audit trend of separate analysis

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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