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Multinational enterprise (MNE) groups almost always require a broad range of services to support their operations—covering administrative, technical, financial, and commercial needs.

As global tax regimes increasingly prioritise transparent reporting, responsible governance, and sustainable development, the convergence of Environmental, Social, and Governance (ESG) principles, sustainability goals, and Advance Pricing Agreements (APA) within transfer pricing (TP) frameworks is emerging as a strategic imperative.

The Bureau of Internal Revenue (BIR) has announced that it will conduct a public consultation on the draft Revenue Regulations governing the Advance Pricing Agreement (APA) on August 28, 2025.

As the Philippines reels from the successive landfalls of Typhoons Crising, Dante, and Emong, and the relentless southwest monsoon (Habagat), businesses across the archipelago are once again reminded of nature’s unforgiving power.

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.