Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's-Length Transfer Pricing Article 35

In the event that the collection authorities-in-charge have conducted an investigation pursuant to the Regulations with respect to the revenue, costs, expenses, or the profit and losses allocation of the Controlled Transaction conducted by a profit-seeking enterprise, and the Arm’s-length adjustments have been assessed and approved by the MOF or the competent authorities as set forth in Article 50 of the Financial Holding Company Act, the collection authorities-in-charge shall make corresponding adjustments to the counter-party of the Controlled Transaction provided that it is a taxpayer under ROC tax jurisdiction.
中文原文 營利事業所得稅不合常規移轉訂價查核準則第35條
從事受控交易之營利事業,有關收益、成本、費用或損益攤計之交易,經稽徵機關依本準則規定進行調查,並報經財政部或金融控股公司法第五十條規定之主管機關核准按營業常規或交易常規調整且經核課確定者,其交易之他方如為依本法規定應繳納中華民國所得稅之納稅義務人,稽徵機關應就該納稅義務人有關之交易事項進行相對之調整。

English translation for reference only; the Chinese text prevails. Not legal advice.