Practice area

World TP Reviews

Transfer pricing

Austin Chen is the managing partner and serves in the transfer pricing team at Deloitte Taiwan. The main professionals are Austin Chen, Ye-Hsin Lin, Al Chang and Ming Chang. Al Chang is a leading APA advisor in Taiwan. Ming Chang, a transfer pricing leader, offers transfer pricing related consultation, transfer pricing benchmarking and documentation service. Deloitte Taiwan has established the BEPS Corner, which helps clients to access the information. It provides promotional videos, BEPS international developments, government response measures, action plan timetables and news. The firm uses technology such as the Deloitte TP Digital DoX, to improve transfer pricing practice efficiency.

Ming Chang and Craig Chou assisted one leading provider of passive components services on a worldwide scale to identify potential tax and transfer pricing risks under the BEPS Action Plan and local tax regulations. It helped the clients implement the master file, Country-by-Country Report (CbCR) and local reports in line with local transfer pricing regulations. In addition, the firm used the Deloitte CDX tool, visualising the potential impact of the CbCR, and helped the client obtain a better insight of the potential tax risks.


EY has more than 40 full time transfer pricing professionals. The firm provides transfer pricing services including controversy management, advisory, APAs, documentation and supply chain profit allocation analysis. The transfer pricing group is well known for assisting many multinational companies with transfer pricing audit defence and reducing additional tax assessments such as withholding tax reduction.

George Chou and Sean Lin assisted a Taiwan-headquartered firm with transfer pricing audit defence and the required analysis of inseparability of transactions. The EY transfer pricing group helped the client prepare the transfer pricing documentation and discussed it with the authority. The result was that there was no need for a royalty charge. In addition it saw the maintenance of regular profit margins in line with the transfer pricing study.

Grant Thornton

With more than 200 professionals in Taipei, Taichung and Kaohsiung, Grant Thornton Taiwan is a member firm of Grant Thornton International. It often participates in cross-border assignments with other Grant Thornton International member firms to serve clients with a global presence. The transfer pricing group often assists clients to review the Taiwan portion of international tax planning work done by other international accounting firms. In 2017, the transfer pricing practice had more than 50 cases, and is expected to grow by 5% in 2018.

In 2018, professional Jay Lo assisted Fox Factory with a tax restructuring review. The team helped the client deal with transfer pricing regulations specific to their Taiwanese firm, avoiding the potential tax risk because of the unique laws and regulations in Taiwan.

One senior specialist left the practice in January 2017.


The transfer pricing group is made up of more than 50 professionals at KPMG Taiwan. It maintains multi-firm collaborations within the integrated KPMG global network. The firm assists clients with their global transfer pricing documentations and overall tax burden management. KPMG Taiwan’s BEPS team stands at the leading position of the BEPS landscape and monitors the updated global information and publications regarding the programme. The transfer pricing team works with the Ministry of Finance, obtaining the knowledge on the progression of international tax matters. 

One project saw Willis Yeh and Chris Lin assisting a leading semi-conductor and electronic products manufacturer to apply for tax refund from Taiwan tax authority following a unilateral APA and tax payment concluded with the Netherlands tax authority. The practice guided the client to revise applications and pursue a tax refund with the Taiwan authorities under Article 9 of the Taiwan-Netherland Double Tax Agreement.