What is Transfer Pricing?
Transfer Pricing (TP) is a taxation practice that refers to the pricing of products and services traded between subsidiaries, affiliates, and other legal entities owned or controlled by the same parent firm. Associated enterprises or related parties are the names given to the managed entities.
TP strives to verify that transactions between linked firms comply with government rules and that the prices paid are equal to the prices charged if the same transaction were undertaken with third parties.
What We Offer
- Review of TP policies and processes
- Assessment of TP risks
- Preparation of TP documentation and attachments
- TP comparability analysis and benchmarking
- Selecting the right TP systems and methods to utilize
- Preparation/restructuring of intercompany agreements, contracts, and agreements
- Assist with TP audit
- TP defense (with our partner law firm)
Up-to-date Transfer Pricing Regulations in the Philippines
To give you guidance about transfer pricing transactions in the Philippines, the Bureau of Internal Revenue (BIR) has issued the following regulations:
- Revenue Regulations (RR) No. 2-2013. Provides guidelines regarding the Arm’s Length Principle application.
- Revenue Audit Memorandum Order (RAMO) No. 1-2019. Provides a structure for Transfer Pricing audits.
- Revenue Regulations (RR) No. 19-2020. When filing BIR Form 1709, also known as the Related Party Transaction (RPT) Form, Transfer Pricing documents must be attached.
Understand Transfer Pricing in the Philippines
Entrepreneurs must be aware of the prices they charge on services and products they offer to their affiliates. Ensuring that the charges they ask are fair in accordance with the law is crucial to avoid possible audit questions from BIR.
Our Philippine tax consultants are always up-to-date on the latest Transfer Pricing legislation in the Philippines, skilfully navigating in streamlining your tax obligations with the government.
Frequently Asked Questions
Why Should Taxpayers Comply with Transfer Pricing?
Transfer Pricing compliance is important to have fair pricing policies. By complying with TP regulations we can have a more stable and sustainable tax system that will benefit both business owners and everyone in the society.
Who Imposes the Rates for TP?
There is no permanent rate when it comes to transfer pricing. However, the BIR decides how much to charge the companies based on the guidelines set by the Organization for Economic Cooperation and Development (OECD).
What are the Penalties for Non-compliance Violations?
Late filing or non filing of BIR form 1709 can result in a fine of not less than P1,000 but not more than P25,000. Depending on the violation the penalties can range from fines to imprisonment.
Streamline Your Transfer Pricing Obligation Compliance in the Philippines
Our skilled tax consultants can help you have hassle free compliance with your transfer pricing obligations in the Philippines.