Transfer Pricing Services in the Philippines for Local and Foreign Enterprises

We provide Transfer Pricing (TP) Services to local and foreign companies doing business in the Philippines. Our tax consultants have solid years of experience in assisting clients with streamlining their tax obligations with the government, from assessing TP risks to preparing TP documentation and providing tax advisory on possible audit questions from BIR. 

Our Philippine tax consultants are constantly up-to-date with the latest regulations on Transfer Pricing in the Philippines, expertly navigating the government’s complicated approach to TP that is currently in its early stage of development.   

What is Transfer Pricing?

Transfer Pricing (TP) is a taxation practice that refers to the setting of prices on goods and services exchanged among subsidiaries, affiliates, and other legal entities owned or operated by the same parent company. The managed entities are known as associated enterprises or related parties. 

TP seeks to ensure the transactions among associated enterprises comply with government regulations and the prices charged are equivalent to the prices they would be charged with if the same transaction is conducted with third parties.  

Our Transfer Pricing Services in the Philippines

• 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)

Latest Transfer Pricing Regulations in the Philippines

The Bureau of Internal Revenue (BIR) prescribes Revenue Regulations (RR) No. 2-2013, Revenue Audit Memorandum Order (RAMO) No. 1-2019, and Revenue Regulations (RR) No. 19-2020 to provide guidance for transfer pricing transactions in the Philippines. 

RR No. 2-2013 provides guidelines for the application of the Arm’s Length Principle; RAMO No. 1-2019 provides a framework for Transfer Pricing audits; and RR No. 19-2020 requires the attachment of Transfer Pricing documentation when filing BIR Form 1709, otherwise known as the Related Party Transaction (RPT) Form.