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The Philippine regulatory framework for transfer pricing (TP) in the context of business restructuring is primarily governed by Revenue Audit Memorandum Order (RAMO) No. 1-2019.

In this article, we’ll explore the key issues flagged by the BIR in an actual transfer pricing audit, how the taxpayer was able to address these findings, and what steps can be taken to prevent similar issues in the future.

Kudos to all taxpayers and their finance teams who successfully finalized and filed their income tax returns (ITRs) on time! To all accountants, you deserve hearty congratulations for a job well done. Take a much-deserved vacation break to recharge and relax.

When we hear the term "profit shifting", we often associate it with cross-border transactions between and among members of multinational companies (MNEs) aimed at reallocating profits across different countries or tax jurisdictions to minimise tax liabilities.

When a group of companies work together, each member contributes their unique strengths and skills to achieving common goals through helping each other.

The rampant development of digitalization and globalization in the 21st century brought with it several challenges to the rules for taxing international business income, which gave rise to base erosion and profit shifting (“BEPS”), where multinational entities (“MNEs”) shift profits to locations with minimal or no tax to pay a reduced amount of global taxes.

Today marks the last day of 2024. As we bid farewell to 2024, let me wrap up the key topics and insights discussed in our monthly Let’s Talk TP articles throughout the year. From the implications of BEPS Pillar 2 to the intricacies of intercompany financial transactions, we explore the critical issues surrounding transfer pricing.

The Philippine tax landscape faces a similar turning point, where significant tax amendments are being introduced to allow our tax system to flourish.