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 2026

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

A recent hiring flurry has taken the firm’s number of partner appointments this year to 121 and put it on track to hit 160 partner target early
The move brings specialist tax and litigation capability to EY as it seeks to close the gap on Baker McKenzie and Venezuela’s leading local firms
The industry’s response to AI requires an unfamiliar ingredient as firms battle to shape their futures
The ambitious big four challenger firm has also appointed ex-RSM partner Brad Ashton to build out its customs and global trade practice
The big four firm allegedly reviewed backdated documents and signed off on accounts that removed hundreds of millions of dollars of Abramovich’s assets
New Tier 1 entrants and an expanding cohort of established players indicate that law firms are becoming increasingly credible challengers in Europe's TP market
Awards
Leading firms and individuals gathered in Dubai to celebrate standout legal, dealmaking and tax work across the region
Tax authorities want more revenue, have better tools to find it and are increasingly willing to fight for it
Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for
Gift this article