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Transfer Pricing Services in the Philippines
Optimize transfer pricing planning, documentation, benchmarking, and compliance services for both local and international companies operating in the Philippines.
Transfer Pricing Services
Formal Evaluation of Transfer Pricing Policies and Internal Procedures
We review your current transfer pricing policies, internal procedures, and transaction flows to evaluate their alignment with your organisation’s business model and related party arrangements.
Comprehensive Assessment of Transfer Pricing Risks
We conduct a thorough assessment of the transfer pricing risks pertinent to your organisation, taking into account the specific characteristics of your related party transactions, the jurisdictions involved, the availability of pricing support, and the existing compliance environment in the Philippines.
Preparation of Formal Transfer Pricing Documentation
We provide comprehensive assistance in the preparation of transfer pricing documentation and all requisite supporting attachments for enterprises engaging in related party transactions within the Philippines.
Formal Comparability Analysis and Benchmarking Procedures
We undertake rigorous comparability analyses and benchmarking exercises to support the arm’s length character of relevant transactions, employing a structured and methodical approach tailored to the complexities of your organisation’s operations.
Formal Selection of Appropriate Transfer Pricing Methodologies
We offer expert guidance in selecting the most appropriate method, grounded in a thorough analysis of the specific facts and circumstances of the transaction, the availability of financial data, and the functions, assets, and risks assumed by each party.
Formal Review and Structuring of Intercompany Agreements and Contracts
We provide comprehensive assistance in the preparation, review, and restructuring of intercompany agreements to ensure these accurately reflect the commercial relationships between related parties.
Formal Advisory and Compliance Support for BIR Form 1709
We provide expert assistance with the mapping, preparation, and critical review of all records necessary to support the disclosure of related party transactions, ensuring your organisation’s compliance with the relevant statutory requirements.
Formal Advisory and Support for Transfer Pricing Audits
We provide comprehensive assistance in the organisation of pertinent records, clarification of the background to each transaction, and guidance to internal teams in formulating a clear, well-supported response.
Role of Transfer Pricing in Corporate Entities
- Goods: The sale or transfer of physical products or inventory between related entities within the corporate group.
- Services: The provision or receipt of administrative, technical, management, or support services between affiliated parties.
- Loans: Intercompany financing arrangements such as advances, borrowings, or credit facilities made available between related parties.
- Royalties: Payments for the use of intellectual property, such as trademarks, patents, or proprietary technology, within the same corporate structure.
- Other financial or commercial arrangements: Any additional intragroup dealings, including cost-sharing, guarantees, or arrangements that affect the allocation of income and expenses within the group.
BIR Transfer Pricing Regulations in the Philippines
Revenue Regulations No. 2-2013
Serves as the principal guidance regarding the application of the arm’s length principle to transactions conducted between related parties.
Offers authoritative guidance on the application of the arm’s length principle in transactions conducted between related parties, establishing baseline expectations for compliance and documentation within the Philippine regulatory context.
Revenue Audit Memorandum Order No. 1-2019
Establishes the official framework employed in the conduct of transfer pricing audits, with particular emphasis on the procedures and methodologies the tax authorities may use to evaluate related party transactions within corporate entities.
It establishes the prescribed procedures for transfer pricing audits and outlines the approaches the tax authority may employ when evaluating related party arrangements within corporate entities.
Revenue Regulations No. 19-2020
Requires the disclosure of related party transactions through BIR Form 1709 and mandates the preparation and submission of transfer pricing documentation when requested by the BIR.
Revenue Regulations 34-2020
Introduces and clarifies updated guidelines for transfer pricing documentation requirements in the Philippines.
This regulation outlines what information needs to be included, the standard for supporting analysis, and the timing for submission, all with the aim of ensuring greater consistency and transparency in the reporting of related party transactions.
Why Choose Ascentium Philippines
We possess a detailed understanding of the Philippine transfer pricing regulatory environment, furnishing clients with authoritative advice on compliance expectations, BIR reporting requirements, and related statutory obligations.
We deliver clear, precise guidance on transfer pricing requirements, enabling your organisation to understand applicable obligations, requisite documentation, and principal areas of risk with accuracy and confidence.
Our professionals provide thorough assistance in organising transfer pricing records, related party transaction files, and supporting documents, ensuring they are structured for effective reporting, internal review, and preparedness for regulatory assessment.
Transfer Pricing Solutions by Experts
Our team possesses extensive, practical expertise in transfer pricing, tax advisory, regulatory documentation, and corporate compliance within the Philippine setting.
Our Other Corporate and Advisory Services
Corporate Secretarial Services
Ongoing statutory compliance, SEC filings and corporate housekeeping.
Payroll Services
Payroll administration, statutory contributions, and employment compliance.
Frequently Asked Questions (FAQs)
Transfer pricing is formally defined as the process of determining the prices to be applied to goods, services, and other transactions that occur between related parties, such as subsidiaries, affiliates, or entities under common ownership or control.
BIR Form 1709, formally referred to as the Related Party Transaction Form, is required for the disclosure of specified related party transactions within the Philippines.
Non-compliance with transfer pricing rules can increase the risk of BIR assessment, audit issues, and tax adjustments.
Domestic and foreign companies that engage in related party transactions in the Philippines may need transfer pricing documentation. This applies to businesses dealing with subsidiaries, affiliates, parent companies, or other entities under common ownership or control, especially when Philippine tax rules and BIR requirements are relevant.
It is advisable to review and update your documents annually, or whenever there are significant changes in your business, transactions, or group structure.
Transfer pricing services help your business manage compliance, reduce tax risk, and support related party transactions with clear, defensible documentation.
We help with every step of the transfer pricing process, from reviewing your policies and assessing risks, to preparing documentation and benchmarking analysis. Our team also assists with intercompany agreements, BIR Form 1709, and getting you ready for audits, making compliance easier for your business.
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