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法律與法規命令

Tax Act:
Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's-Length Transfer Pricing<br> Article 19-1
Content:
The Income-based Approach prescribed in the Regulations refers to the situation where the Arm's-length Price of a Controlled Transaction is determined based on the basic standards, relevant method of Income-based Approach, explanations and application, evaluation reports, and disclosure regulations set out in the Statements of Valuation Standards NO.7 “Valuation of Intangible Assets” announced by the Accounting Research Development Foundation when profit-seeking enterprises conduct Controlled Transactions for transfer or use of Intangible Assets.
When evaluating the applicability of the Income-based Approach, the factors prescribed in Paragraph 1 of Article 8 shall be considered, particularly the following assumptions:

1. 

accuracy and reliability of financial projections;

2. 

growth rate;

3. 

discount rate;

4. 

remaining economic life;

5. 

assumptions regarding taxes; and

6. 

other assumptions affecting the evaluation of Intangible Assets.
 Update:2021-03-23

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