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Philippine transfer pricing regulations still under review

Draft revenue regulations for transfer pricing in the Philippines are still under review by the Department of Finance for final approval and issuance, despite rumours they would be published by the end of 2012.

The draft has not yet been made available to the public or practitioners in the Philippines.

The Philippine Bureau of Internal Revenue (BIR) first submitted a draft for formal transfer pricing regulations for the secretary of finance’s approval in 2006.

The draft regulations are based on the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations issued by the OECD (OECD transfer pricing guidelines).

If approved, the draft regulations will implement the authority of the commissioner of internal revenue, under section 50 of the National Internal Revenue Code (NIRC), to review controlled transactions among related parties and to allocate/distribute relates parties’ income and deductions to determine the true taxable income of the related parties involved in the controlled transactions.

The Philippines is the only significant Asia-Pacific economy not to have implemented transfer pricing regulations.

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