In line with international tax trends, the Taiwan Ministry of Finance (MOF) on June 24 issued a Decree (Tai Tsai Ji No. 11024508100) which grants flexibility for income adjustments for cross-border bilateral or multilateral advance pricing arrangements (BAPAs). The new Decree stipulates that when the Taiwan tax authorities negotiate cross-border BAPAs with the competent authorities of the treaty partners, both authorities may determine the method of examining whether the controlled transactions fall within the arm's-length range. They can adopt the results of the controlled transactions either on a year-by-year basis or using the average results of the controlled transactions of the covered years as a whole.
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