For foreign and domestic investors, selling shares in Philippine companies have always been fraught with difficulty and uncertainty. In the past, the most complex issue has been the determination of the fair market value of the shares to be sold. The rules created various complications and requirements that sellers and buyers had to be aware of before even considering the transaction. Hence, any move to simplify the process is certainly a welcome development. One of these new developments is Revenue Regulations 20-2020 (RR 20-20) published on Aug. 19. The revenue regulations make the determination of fair market value relatively easier for shareholders selling shares.
The year 2020 is like no other. With a pandemic still raging, a volcanic eruption, explosions, wildfires, plane crashes, social unrest, tragic deaths, and many other unexpected events — each one of us is affected one way or another. The year is not yet over but it has dished out something out of the ordinary to each and every one of us.
The global pandemic COVID-19 has proven to have an arduous effect on our society and economy. Recently, the Philippine government presented a range of different measures to combat against the danger of the COVID-19 virus. Among these are the imposition of quarantine measures such as the Enhanced Community Quarantine (ECQ), Modified Enhanced Community Quarantine (MCQ) and General Community Quarantine (GCQ) and travel restrictions.
Human society is composed not only of the privileged, the wise, and the good, but also of the vulnerable.
Last month, I wrote an article about the saga of transfer pricing in the Philippines. The tale begins in 1939 when the Commonwealth Act 466 or the “National Internal Revenue Code was passed. This is the source of the Commissioner of Internal Revenue’s (CIR) authority to review, allocate and distribute the income and deductions of related-party transactions (RPT), both cross-border and domestic, including intra-firm transactions between related parties, to determine the appropriate revenue and taxable income.
It has been almost five months since the implementation of the community quarantine due to the COVID-19 pandemic. Most of us had no choice but to stay indoors. Thus, we were forced to entertain, educate, and make ourselves useful within our homes. With the help of the internet and other electronic platforms, we got to binge-watch our favorite shows, shop, buy groceries, start on our fitness goals, finish online courses, play online games, etc. Netflix, Google, Amazon, and even YouTube have somehow helped us to hold on to our sanity during these challenging times.
Nearly a month ago, many taxpayers finally put an end to the longest tax season when they finally submitted their annual income tax returns (ITRs). Others, however, have to brace for the submission of a new set of attachments to the ITR. These refer to the Bureau of Internal Revenue (BIR) Form No. 1709 or the Information Return on Related Party Transactions (Domestic and/or Foreign) and its related attachments, as prescribed by Revenue Regulations (RR) No. 19-2020. RR No. 19-2020 requires not only the proper disclosure of related-party transactions, but also the documents that would support that these transactions have been conducted at arm’s length.
According to Greek philosopher Heraclitus, “The only constant in life is change.” In Japanese, business people believe that constant, increasing improvement adds to substantial change over time. “Kaizen” is a Japanese productivity philosophy that means continuing development in personal, family, social, and professional life. The word “kaizen” comes from the two words: “kai,” which means “change,” and “zen,” which means “for the better.”