Philippine transfer pricing regulations still under review

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

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.

more across site & shared bottom lb ros

More from across our site

The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
Gift this article