Wednesday October 18 , 2017

Transfer Pricing and Tax Treaty Applications

Transactions of local affiliates, subsidiaries and branches of multinational enterprises with their head offices, parent or other members of the group may attract transfer pricing issues or/and tax treaty application.

The Philippines adheres to the OECD rules on transfer pricing. Although the draft comprehensive regulation for transfer pricing is still pending with the Department of Finance, there have already been several assessments issued by the Tax Bureau challenging the transfer pricing policies adopted by taxpayers.

For the application of the provisions of the tax treaty, the Philippine Tax Bureau requires that a confirmatory ruling be secured from them.

How can we help?

Transfer Pricing Studies and Defense

Managing related party transactions is increasingly critical. We provide comprehensive transfer pricing solutions, based on OECD guidelines and local country rules. Our transfer pricing team can assist you through transfer pricing risk assessment, planning and benchmark analysis, selecting the appropriate transfer pricing method, and negotiating Advance Pricing Agreements (APAs) with the tax authorities. We can also assist in defending transfer pricing policies and in handling transfer pricing audit defense on your behalf.

Application for Ruling involving availment of tax treaty provisions

Application of preferential rates of withholding taxes on income payments to non-resident aliens and foreign corporations pursuant to tax treaties, or the application of any tax treaty provision may require a prior application for a ruling from the tax bureau. We can assist you in securing the required ruling.