Dec 062015
 

(Second of two parts) In last week’s column, we started our discussion on Base Erosion and Profit Shifting (BEPS) Action Plan 10, which seeks to align transfer pricing outcomes to value creation by providing protection to payor-countries against base-eroding payments and prescribing additional rules on the applicability of the profit split method.

Dec 022015
 

More than a decade ago, a taxpayer could expect only one tax investigation by the Bureau of Internal Revenue (BIR) in a given year, and seldom for two successive years. But now, a taxpayer can be investigated up to three times in the same year: first, under a normal tax audit (i.e., covering all taxes); second, under a value-added tax (VAT) audit; and third, under a Letter Notice audit (which is based on discrepancies arising from the computerized matching of data between the taxpayer’s records and its customers and suppliers).