Philippine Transfer Pricing Rules in Business Restructuring
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.

Makati
Partner, Tax Advisory & Compliance; Transfer Pricing Head
Nikki is a Partner in P&A Grant Thornton’s Tax Advisory and Compliance Practice Area. He is also the head of the Firm’s Transfer Pricing team.
Nikki has been with P&A Grant Thornton since he started his professional career in 2007. He has gained extensive experience in providing tax compliance/due diligence audit and tax outsourcing services to local and multinational companies. He has also crafted tax studies and opinions, as well as transfer pricing studies, for several clients.
Nikkolai completed his bachelor's degree in accountancy, summa cum laude, from the Far Eastern University - Manila. Nikki earned a Postgraduate Certificate in General Management, a Postgraduate Certificate in Business Management and Transformation, and a Postgraduate Diploma in Management at the Asian Institute of Management (AIM).
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.
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.
In last week’s article, my colleague discussed the new rules on the treatment of foreign currency transactions for internal revenue tax purposes. That article provided clarifications and guidelines on the use of appropriate forex rates in recording and reporting foreign currency transactions for tax purposes.
Partner, Tax Advisory & Compliance; Transfer Pricing Head