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Across a number of countries, the way internationally mobile employees are taxed is being shaken-up. This follows the G20/OECD-led Base Erosion and Profit Shifting (BEPS) Action Plan recommendations set out over a year ago.

We may therefore be allowed to wonder, how will the BIR conduct the transfer pricing audit? What is the advantage of having transfer pricing documentation? How will the transfer pricing documentation affect our tax treaty relief application (TTRA)?

Grant Thornton article discussing the impact of the Foreign Account Tax Compliance Act (FATCA) on non-US companies.