Taiwan’s Ministry of Finance (MOF) Northern District National Taxation Bureau has announced the implementation of new compliance requirements for business entities issuing electronic invoices. Beginning January 1, 2025, sellers who process returns, purchase withdrawals, or discounts through mutual agreement with buyers must issue and upload an Electronic Invoice Allowance Note (EIAN)折讓單 to the E-Invoice Integrated Service Platform within a legally defined time frame.
The new measure aims to enhance tax transparency, digital recordkeeping, and accuracy in transaction data while streamlining tax deduction and accounting processes for both sellers and buyers.
Understanding Taiwan’s New Regulation
Under the revised framework, once a seller issues an electronic invoice for goods or services, any subsequent sales returns, purchase withdrawals, or price adjustments (allowances) must be formally recorded through an electronic allowance note. This note serves as an official record of the adjustment and must be transmitted to the government’s central e-invoice database.
Key Highlights of Taiwan New Requirement
- Effective Date: January 1, 2025
- Responsible Party: Seller (business entity)
- Scope: Sales returns, purchase withdrawals, or agreed discounts following the issuance of an e-invoice
- Transmission Method: Internet or other approved electronic channels
- Destination: E-Invoice Integrated Service Platform (the official MOF database)
- Purpose: Recordkeeping for tax reporting, accounting, and deduction claims
Both sellers and buyers may later download stored allowance records from the platform to serve as valid proof when filing tax returns, claiming deductions, or maintaining financial records.
Taiwan’s Legal Basis and Compliance Deadlines
The Bureau clarified that the new rule is grounded in Article 32-1, Paragraph 4 of Taiwan’s Value-Added and Non-Value-Added Business Tax Act. It aligns with the provisions under the “Scope and Time Limit for Information Transmission of Electronic Invoices to the Ministry of Finance’s E-Invoice Integrated Service Platform” regulation.
Submission Time Limits in Taiwan
- When the buyer is a non-business entity:
The seller must upload the electronic invoice allowance note within 2 days from the day after issuance.
- When the buyer is a business entity:
The upload must be completed within 7 days from the day after issuance.
Failure to comply with these deadlines could result in administrative penalties, unless the case qualifies for exemption under Article 16-3 of the Standards for Reduction or Exemption of Fines for Tax Violations.
Penalty Range in Taiwan
According to Article 48-2 of the Business Tax Act, sellers who fail to upload data truthfully within the prescribed time limit may face a fine ranging from NT$1,500 to NT$15,000.
The Bureau emphasized that these measures are not only regulatory but also part of a broader initiative to modernize Taiwan’s digital tax infrastructure and ensure the authenticity of electronic financial records.
Importance of Recordkeeping and Data Retention in Taiwan
The Northern District National Taxation Bureau also highlighted the importance of maintaining thorough documentation when conducting transactions that involve returns or discounts through electronic communication channels.
When a seller issues an e-invoice and later agrees with the buyer—via a website, telephone, email, or other electronic means—to return goods or adjust prices, the seller must retain all supporting materials in compliance with Point 9 of the “Operational Guidelines for the Implementation of Electronic Invoices.”
This includes:
- Records of the buyer’s and seller’s mutual consent
- Corresponding electronic messages or system logs
- Any other supporting documentation evidencing the transaction adjustment
All such records must be kept on file for at least five years to facilitate future tax audits or verification procedures.
Taiwan’s End of the Counseling Period and Full Enforcement
Recognizing that many sellers might need time to update their internal systems to accommodate the new process, the Ministry of Finance previously introduced a counseling period between January 1, 2025, and June 30, 2025.
During this grace period, businesses were encouraged to:
- Adjust their information systems and accounting workflows;
- Ensure seamless integration with the E-Invoice Integrated Service Platform; and
- Train staff on the issuance and transmission of electronic allowance notes.
The Bureau has now confirmed that the counseling period has officially ended, and full enforcement of the regulation is in effect. Businesses that fail to comply from July 1, 2025, onward may be subject to fines.
To avoid penalties, the Bureau urges all sellers to ensure that any returns or discounts are mutually agreed upon and that all related data is accurately and promptly uploaded to the official platform for verification and recordkeeping.
Why Taiwan’s E-Invoice Change Matters for Businesses
The implementation of this regulation marks another milestone in Taiwan’s transition toward a fully digitalized tax environment. Since the introduction of electronic invoices, the government has continuously sought to enhance automation, accuracy, and transparency in commercial transactions.
This new rule ensures that all adjustments—such as returns and discounts—are formally captured within the same electronic framework as the original transaction.
Benefits for Sellers in Taiwan
- Reduced Paperwork: Digital processing minimizes manual documentation.
- Improved Accuracy: Automatic data synchronization between seller and government records.
- Faster Tax Reconciliation: Simplified tax deduction and accounting validation.
- Legal Protection: Proper recordkeeping reduces the risk of disputes during audits.
Benefits for Buyers in Taiwan
- Verified Records: Easy access to allowance notes for deduction or refund claims.
- Transparency: Clear documentation of any price adjustments or returns.
- Convenience: Instant download of verified data from the MOF platform.
Taiwan Compliance Best Practices for Business Entities
To help sellers adapt effectively, the Bureau recommends several best practices for compliance:
- Update Accounting Software: Ensure that your enterprise resource planning (ERP) or accounting system is capable of automatically generating and uploading electronic allowance notes.
- Integrate with the MOF Platform: Use authorized APIs or data transfer methods to synchronize information in real time.
- Train Staff Regularly: Equip accounting and sales personnel with up-to-date knowledge on e-invoice regulations.
- Keep Consent Records Securely: Store electronic consent messages and supporting files for a minimum of five years.
- Monitor Upload Deadlines: Establish internal reminders or automated alerts for the 2-day or 7-day upload deadlines.
- Conduct Periodic Compliance Audits: Review your company’s electronic invoicing processes to ensure all transactions are accurately reported.
By adhering to these practices, businesses can ensure smooth compliance while improving internal efficiency and audit readiness.
Conclusion
The new requirement for the issuance and timely upload of electronic invoice allowance notes marks a critical advancement in Taiwan’s ongoing tax digitalization initiative. By mandating that all transaction adjustments be recorded electronically and transmitted to the E-Invoice Integrated Service Platform, the government aims to strengthen tax compliance, data integrity, and financial transparency.
With the counseling period now concluded, full compliance is essential. Sellers are strongly advised to review their internal systems, ensure mutual agreement with buyers prior to any returns or discounts, and adhere strictly to upload timelines.
Ultimately, this transition to an all-digital invoicing ecosystem not only supports national fiscal governance but also helps businesses achieve greater efficiency, accuracy, and reliability in their financial operations.