Services
We deliver value-added audit and assurance services to our clients, helping them manage their fiscal responsibilities with prudence and foresight.
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Audit approach overview
Our audit approach will allow our client's accounting personnel to make the maximum contribution to the audit effort without compromising their ongoing responsibilities
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Annual and short period audit
At P&A Grant Thornton, we provide annual and short period financial statement audit services that go beyond the normal expectations of our clients. We believe strongly that our best work comes from combining outstanding technical expertise, knowledge and ability with exceptional client-focused service.
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Review engagement
A review involves limited investigation with a narrower scope than an audit, and is undertaken for the purpose of providing limited assurance that the management’s representations are in accordance with identified financial reporting standards. Our professionals recognize that in order to conduct a quality financial statement review, it is important to look beyond the accounting entries to the underlying activities and operations that give rise to them.
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Other Related Services
We make it a point to keep our clients abreast of the developments and updates relating to the growing complexities in the accounting world. We offer seminars and trainings on audit- and tax-related matters, such as updates on Accounting Standards, new pronouncements and Bureau of Internal Revenue (BIR) issuances, as well as other developments that affect our clients’ businesses.
We help you identify the opportunities and pitfalls that can significantly affect your...
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Tax advisory
With our knowledge of tax laws and audit procedures, we help safeguard the substantive and procedural rights of taxpayers and prevent unwarranted assessments.
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Tax compliance
We aim to minimize the impact of taxation, enabling you to maximize your potential savings and to expand your business.
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Corporate services
For clients that want to do business in the Philippines, we assist in determining the appropriate and tax-efficient operating business or investment vehicle and structure to address the objectives of the investor, as well as related incorporation issues.
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Tax education and advocacy
Our advocacy work focuses on clarifying the interpretation of laws and regulations, suggesting measures to increasingly ease tax compliance, and protecting taxpayer’s rights.
We believe there is an optimal solution to every business challenge.
Using our Firm's breadth and depth of specialized expertise, we work with you to find...
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Business risk services
Our business risk services cover a wide range of solutions that assist you in identifying, addressing and monitoring risks in your business. Such solutions include external quality assessments of your Internal Audit activities' conformance with standards as well as evaluating its readiness for such an external assessment.
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Business consulting services
Our business consulting services are aimed at addressing concerns in your operations, processes and systems. Using our extensive knowledge of various industries, we can take a close look at your business processes as we create solutions that can help you mitigate risks to meet your objectives, promote efficiency, and beef up controls.
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Transaction services
Transaction advisory includes all of our services specifically directed at assisting in investment, mergers and acquisitions, and financing transactions between and among businesses, lenders and governments. Such services include, among others, due diligence reviews, project feasibility studies, financial modelling, model audits and valuation.
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Forensic advisory
Our forensic advisory services include assessing your vulnerability to fraud and identifying fraud risk factors, and recommending practical solutions to eliminate the gaps. We also provide investigative services to detect and quantify fraud and corruption and to trace assets and data that may have been lost in a fraud event.
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Cyber advisory
Our focus is to help you identify and manage the cyber risks you might be facing within your organization. Our team can provide detailed, actionable insight that incorporates industry best practices and standards to strengthen your cybersecurity position and help you make informed decisions.
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ProActive Hotline
Providing support in preventing and detecting fraud by creating a safe and secure whistleblowing system to promote integrity and honesty in the organisation.
We provide solid, first-rate support for your key accounting and administrative activities, such as outsourced accounting, payroll, and accounting-related...
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Accounting services
At P&A Grant Thornton, we handle accounting services for several companies from a wide range of industries. Our approach is highly flexible. You may opt to outsource all your accounting functions, or pass on to us choice activities.
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Staff augmentation services
We offer Staff Augmentation services where our staff, under the direction and supervision of the company’s officers, perform accounting and accounting-related work.
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Payroll Processing
Payroll processing services are provided by P&A Grant Thornton Outsourcing Inc. More and more companies are beginning to realize the benefits of outsourcing their noncore activities, and the first to be outsourced is usually the payroll function. Payroll is easy to carve out from the rest of the business since it is usually independent of the other activities or functions within the Accounting Department.
Japan Desk
With our unique culture and opportunities, our organisation is a place where you can grow. Wherever you are in your career, we help you to make a difference...
We value each of the 50,000 people in our member firms equally and appreciate every contribution across Grant Thornton.
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Our values
Grant Thornton prides itself on being a values-driven organisation and we have more than 38,500 people in over 130 countries who are passionately committed to these values.
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Global culture
Our people tell us that our global culture is one of the biggest attractions of a career with Grant Thornton.
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Learning & development
At Grant Thornton we believe learning and development opportunities allow you to perform at your best every day. And when you are at your best, we are the best at serving our clients
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Global talent mobility
One of the biggest attractions of a career with Grant Thornton is the opportunity to work on cross-border projects all over the world.
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Diversity
Diversity helps us meet the demands of a changing world. We value the fact that our people come from all walks of life and that this diversity of experience and perspective makes our organisation stronger as a result.
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In the community
Many Grant Thornton member firms provide a range of inspirational and generous services to the communities they serve.
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Behind the Numbers: People of P&A Grant Thornton
Discover the inspiring stories of the individuals who make up our vibrant community. From seasoned veterans to fresh faces, the Purple Tribe is a diverse team united by a shared passion.
If you wish to develop your talents to the fullest and build a fulfilling career, join P&A Grant Thornton, where you will be part of a dynamic...
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Fresh Graduates
Fresh Graduates
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Students
Whether you are starting your career as a graduate or school leaver, P&A Grant Thornton can give you a flying start. We are ambitious. Take the fact that we’re the world’s fastest-growing global accountancy organisation. For our people, that means access to a global organisation and the chance to collaborate with more than 40,000 colleagues around the world. And potentially work in different countries and experience other cultures.
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Experienced hires
P&A Grant Thornton offers something you can't find anywhere else. This is the opportunity to develop your ideas and thinking while having your efforts recognised from day one. We value the skills and knowledge you bring to Grant Thornton as an experienced professional and look forward to supporting you as you grow you career with our organisation.
If you would like to join Grant Thornton, you may have a few questions about our organisation, how we do business, our culture and our global opportunities....
By ensuring that our clients are matched with professionals most familiar with their industry, P&A Grant Thornton aims to provide a seamless onboarding...
Emerging markets and shifting consumer demand are creating new opportunities in food and beverage, with business leaders investing in new products, markets,...
Our vision is to help learning institutions and business organisations go beyond and create powerful learning cultures through technology integration,...
Energy markets worldwide are undergoing major changes. P&A Grant Thornton can help you understand and navigate ensuing challenges and make sure you have the...
Optimism is slowly returning to the global economy, but the financial services industry needs to regain the trust of public and private bodies. To truly go...
Across the globe, not for profit organisations are increasingly expected to deliver more, while at the same time facing cuts in government funding and...
The outsourcing industry is one of the fastest growing sectors in the Philippines. Growth in the industry is at an annual average rate of 20%. The industry is...
Across the globe, countries are moving towards leaner, more commercial, locally focused, and responsive government and public sectors. At P&A Grant Thornton,...
Opportunity and optimism have emerged within the retail estate and construction industry. At P&A Grant Thornton, it’s our goal to help you benefit from these...
At P&A Grant Thornton, we’ll work with you to capitalise on all opportunities, manage the inherent risks the industry has to offer, and provide relevant...
Dynamic businesses need to move with speed and purpose if they want to capitalise on opportunities in hospitality and tourism. At P&A Grant Thornton, we know...
With operational cost, price competition, and currency volatility, pressure on profits continues to pile on retailers. Advancements in e-commerce are also...
国外関連取引で生じる損失について
04 Jun 2025
関連会社間取引において特定の子会社が継続的に損失を計上する場合、独立企業間価格の原則に違反していないか、注意を払う必要があります。
通常、独立した企業は一時的に事業損失が発生する取引を許容したとしても、無制限に続けることはありません。
関連会社間取引において、特定の企業で事業損失が継続する場合、価格算定が「独立企業間価格の原則」から外れ税務コンプライアンス違反している可能性があります。
国税庁（BIR）は、損失が合理的な範囲を超えて持続する場合、または他の企業と比較して損失期間が長期化している場合、移転価格調査行う可能性があります。
Key Point
経済的実態：損失が発生する取引がすべて税務コンプライアンス違反とみなされるわけではありません。しかし、経済的実態を反映した「独立企業間価格の原則」に基づく取引価格設定が求められます。
一貫した処理：企業が、一定のリスクを負ったうえで取引を行う場合は、取引が成就すれば利益が計上され、リスクが実現した場合当然その損失が計上されることも想定されます。
比較分析：関係会社間取引の取引価格が「独立企業の原則」と一致しているかどうかを判断するため、他企業との類似取引と比較分析が求められます。この分析には、関係する当事者の機能、資産、および取引のリスクの検討が含まれます。
意図的な租税回避：ガイドラインは、企業グループ全体の税負担を最小限に抑えることを目的に、高税率の国から低税率の国に意図的な課税回避が行われないように強く求めています。関連会社取引から生じる損失は、実際の経済活動およびリスクを反映した独立企業間価格によって生じる損失であることが求められます。
文書化：多国籍企業は、移転価格ポリシーおよび取引から生じる損失をサポートするため、より詳細な文書を準備する必要があります。取引から生じる損失の合理性について文書化し、独立企業間価格の原則に準拠していることを示す必要があります。
(OECD移転価格ガイドライン第I章[D.3.]、損失、および国税庁指令No. 1-2019第B.3[b.5]）
移転価格リスクを管理するために、関連会社との移転価格の取り決めを見直し、税務コンプライアンスの順守を確保してください。
損失を合理的な論拠で説明するために、包括的な移転価格文書化が求められます。
ご質問やご不明な点がございましたら、Japan.Desk@ph.gt.com までお問い合わせください。
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