First APA procedures to be released by the Bureau of Internal Revenue (“BIR”) in the Philippines.
In order to meet the criteria for tax collection targets, the BIR is making considerable resources available in order to develop transfer pricing compliance and enforcement regime.
The release of APA guidelines will be followed alongside with the formal transfer pricing documentation guidelines and transfer pricing review and audit guidelines, which are still under progress. A risk-based approach will be taken for the selection of taxpayers for transfer pricing review, emphasizing on loss-making companies, those experiencing loss of after expiry of a tax holiday, or companies paying royalties or service fees to overseas related parties.
