The Bureau of Internal Revenue (BIR) has signaled that it will conduct transfer pricing audits with the promulgation of its Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019. The Transfer Pricing Guidelines were issued in 2013 through Revenue Regulations (RR) No. 2-2013.
The Passive Income and Financial Intermediary Taxation Act (PIFITA) or House Bill No. 304 hurdled the scrutiny of the House Ways and Means Committee a few days ago. If passed into law, PIFITA will amend certain provisions of the National Internal Revenue Code of 1997 (Tax Code) on the taxation of passive income and income of financial intermediaries. PIFITA will be the fourth package of the government’s comprehensive tax reform program.
Authorized or not? This question is very relevant to taxpayers who are subject to a tax audit. One should at least know if the Revenue Officer (RO) conducting the audit investigation is duly armed with a valid Letter of Authority (LoA). The Tax Code, as amended, requires the Commissioner of Internal Revenue (CIR) or their duly authorized representative to issue an LoA if it will delegate the examination of a taxpayer.
In less than two months, I will tie the knot with my girlfriend of eleven years. Looking back, I went through failure, heartache, and disappointment but, at the same time experienced milestones and achievements that made me who I am today. Being with someone I cherish made me a better version of myself. As American author Helen Keller put it, “the best and most beautiful things in the world cannot be seen or even touched — they must be felt with the heart.” It is better to have someone to rely on.
The royalties that you pay relating to the goods that you import may be subject to Customs duties as part of the dutiable value of the importation. Have you made this evaluation? Are you paying duties on those dutiable royalties? Is there a risk that this will be uncovered during a customs audit?
More often than not, employees rely solely on their employers to handle matters involving their registration with government offices, such as the Bureau of Internal Revenue (BIR). Unfortunately, employees sometimes find themselves in a situation where they are made to deal with their registration updates on their own rather than their employers doing it for them. This is normally the case when an employee has recently changed employers. If you have not heard the latest updates from the BIR, you are probably bombarding that staff member from Human Resources (HR) now with questions about how you are supposed to update your BIR registration and why it is you, not them, who should handle the update. If your HR team is well versed in the new procedures, lucky you. But what if they are not? You might then have to resort to Googling, hoping to come across a checklist or set of guidelines to refer to. Look no further, because you have just clicked on the right link with the answer to your problem.
“Options! Options! Options!” – This was one of the lines I would always remember in the movie Four Sisters and a Wedding. The movie revolves around the abrupt decision of CJ, the youngest in the family, to get married to his fiancée, Princess. His four sisters, Teddie, Bobbie, Alex and Gabbie, connived to formulate a plan to stop the wedding from happening. One of which is to provide CJ with other options as the four sisters believed that CJ is only marrying Princess as she was the “best candidate in a diminishing pool of options.”
In less than two months, I will tie the knot with my girlfriend of eleven years. Looking back, I went through failure, heartache, and disappointment but, at the same time experienced milestones and achievements that made me who I am today. Being with someone I cherish made me a better version of myself. As American author Helen Keller put it, “the best and most beautiful things in the world cannot be seen or even touched — they must be felt with the heart.” It is better to have someone to rely on.
