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 Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Gift this article