-
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
-
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.
-
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.
-
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.
-
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.
-
Tax compliance
We aim to minimize the impact of taxation, enabling you to maximize your potential savings and to expand your business.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
Global culture
Our people tell us that our global culture is one of the biggest attractions of a career with Grant Thornton.
-
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
-
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.
-
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.
-
In the community
Many Grant Thornton member firms provide a range of inspirational and generous services to the communities they serve.
-
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.
-
Fresh Graduates
Fresh Graduates
-
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.
-
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.
Separate and Combined Transactions Approach
Transfer pricing compliance begins with a clear understanding of how related parties operate, beyond what is stated in their contracts. This involves identifying key economic characteristics of the transaction such as the functions performed, assets used, and risks assumed, and analyzing the true nature of their financial or business relationships. These elements form the basis for accurately delineating intercompany transactions, which is essential for applying the arm’s length principle.
In preparing transfer pricing documentation, it is also important to assess whether transactions should be grouped or separated. This decision depends on their economic substance, the rationale behind their structure, and the availability of reliable comparable for benchmarking.
Key Points
1. Analyze Actual Conduct
Transfer pricing analysis must consider how related parties actually behave, not just what is written in their contracts. It must clearly reflect the actual conduct and economic rationale behind the transaction. This ensures that the transaction reflects the true nature of the relationship and value creation.
2. Identify Economic Substance
It is essential to examine the functions performed, assets used, and risks assumed by each party. These elements help determine the real economic contribution of each entity involved in the transaction.
3. Evaluation of Separate and Combined Transactions
Transactions may be aggregated or segmented based on their economic interdependence and the feasibility of benchmarking. Ideally, the arm’s length principle should be applied on a transaction-by-transaction basis. However, there are often situations where separate transactions are so closely linked or continuous that they cannot be evaluated adequately on a separate basis.
The following transactions, among others, are generally more appropriately evaluated and analyzed together using the most appropriate arm’s length method:
a. Some long-term contracts for the supply of commodities or services
b. Rights to use intangible property
c. Pricing a range of closely linked products (e.g. in a product line) when it is impractical to determine pricing for each individual product or transaction.
d. Licensing of manufacturing know-how and the supply of vital components to an associated manufacturer
e. Routing of a transaction through another associated enterprise
f. Taxpayers using the portfolio approach as a business strategy (i.e., bundling certain transactions to earn an appropriate return across the portfolio rather than necessarily on any single product). Common examples include printers with cartridges and razors with blade
g. Transactions where it is standard industry practice to set one price for a combination of transactions (e.g., goods and the associated intangible property)
h. Transactions where quality data is reasonably expected to be available to set prices for separate transactions
On the other hand, the following related-party transactions, among others, which are usually contracted as a package, may need to be evaluated separately:
a. Licenses for patents, know-how, and trademarks
b. Provision of technical and administrative services
c. Lease of production facilities.
d. Sales and distribution
e. Repairs and maintenance
f. Regional services.
Ultimately, using either the group or separate transactions approach in applying the arm’s length principle is largely dependent on the nature of the different transactions, the conduct and characterization of the parties, the economic circumstances of the parties and the industry in which they belong, and the functions performed, assets owned, and risks borne by the parties, among others.
(Chapter III, [A.3.1] OECD Transfer Pricing Guidelines 2022, Revenue Audit Memorandum Order No. 1-2019)
To ensure compliance and withstand scrutiny, document intercompany transactions with contracts that reflect the parties’ economic intentions. Remember, delineation is not merely about separating transactions; it’s about achieving clarity and coherence in how they are understood and presented. A well-prepared transfer pricing documentation (TPD) should mirror the BIR’s audit mindset, anticipating questions and addressing them with precision.