Jan 222014
WHEN the Philippine Transfer Pricing (TP) Guidelines (Revenue Regulations [RR] No. 2-2013) were finally issued in January 2013 (after nearly a decade of waiting), it was generally regarded by many as a welcome addition to the roster of administrative issuances and regulations being implemented by the Bureau of Internal Revenue (BIR), especially by multinational enterprises (MNEs) that deal with numerous related parties (i.e. companies belonging to the same group or common controlled companies) from various jurisdictions around the world.