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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.

Businesses, especially multinational companies that have significant transactions with their related parties, can draw a parallel to the importance of remembering transfer pricing regulations.

According to the Organisation for Economic Cooperation and Development (OECD), the use of a cash pool is popular among multinational enterprises as a way of achieving more efficient cash management by bringing together, either physically or notionally, the balances of a number of separate bank accounts.

Technology is making the world smaller. More countries are linked and interconnected in trade relations, particularly in digital trade, which the Organisation for Economic Co-operation and Development (OECD) Global Trade Forum highlighted would continue to grow, representing around 25% of the total trade as of 2020. Likewise, the World Trade Statistical Review reported that digitally delivered services traded within Asia reached 43.2% of the continent’s total trade in 2021.

As each delicate strand of Christmas light is unchanged from the walls, each Christmas ornament is undecked from the halls, and each Christmas tree is carefully dismantled and boxed up, we officially bid a fond farewell to the 2023 holiday season.

One of the first lessons taught in accounting is the concept of ‘substance over form,’ which posits that transactions recorded and presented in financial statements must reflect the economic and factual substance over their legal form. It may be said that substance over form precedes double entry bookkeeping; it is the nexus of all financial transactions and serves as a guide for financial reporters in understanding, recording, and reporting thereof. Even in tax cases, equity and law always exalt substance over form. It is the nature of transactions that determines the taxability of transactions.