Philippine transfer pricing guidelines: Of APAs and MAPs

(Third of three parts)IN THE LAST two columns, we discussed in significant detail the recently released Revenue Regulations No. 2-2013, The Transfer Pricing Regulations (more informally called the TP Regs), which took effect on Feb. 9, 2013. The guidelines are largely based on the Organization for Economic Cooperation and Development (OECD) TP Guidelines, which have served as the framework for TP regulations around the world. In this article, we will now discuss the relevance of the new regulations on Mutual Agreement Procedures (MAPs).