May 012017
 

Since the passage of Republic Act (RA) 10754, An Act Expanding the Benefits and Privileges of Persons With Disability (PWDs), it is only now that disabled members of society will be fully enjoying the benefits granted by this law.
Revenue Regulations No. 5-2017 were approved by the Secretary of Finance upon the recommendation of the Bureau of Internal Revenue (BIR) on April 20. The regulations prescribe the guidelines for the availment and implementation of the 20% discount and the additional exemption as dependents for personal income tax purposes.

Sep 222014
 

AT THE start of the year, the Bureau of Internal Revenue (BIR) issued Revenue Regulations No. (RR) 1-2014 and Revenue Memorandum Circular No. (RMC) 5-2014, which tackled the submission of the alphabetical list (alphalist) of employees and list of payees on income payments subject to creditable and final withholding taxes of all withholding agents. These issuances require that complete names of payees be specified in the alphalists. Using words such as “various payees” and “PCD nominees” where income payments and taxes withheld are lumped into one single amount shall not be allowed and failure to follow such prescribed format shall disqualify the related expenses from being deductible for income tax purposes.

Mar 052014
 

THE BUREAU of Internal Revenue (BIR) has the gargantuan task of collecting P1.4 trillion in tax revenue for 2014. Consequently, various revenue issuances have been circulated to enhance tax compliance and intensify collection efforts. One such issuance is Revenue Memorandum Circular (RMC) No. 11-2014, clarifying certain issues arising from amendments introduced by Revenue Regulations No. 18-2013 on RR 12-99 relative to the tax assessment process. In fine-tuning policy interpretations, the RMC raises several points of interest.

Feb 172013
 

(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).

Feb 042013
 
Transfer mis-pricing: Regulations to address

Intra-related transactions – transactions between related parties or associated enterprises – are a common practice in the globalization of trade. These transactions apply to a parent company and a subsidiary, or two or more companies controlled by a common parent (directly or indirectly and whether or not legally enforceable). When said parties establish a price for the above transactions, they are engaging in Transfer Pricing (TP). TP can be considered to be the most significant tax issue emerging from globalization confronting tax administrations worldwide. This is because related companies are more concerned in their income as a whole rather than as individual corporations, and as such, there is likelihood of manipulating the transfer price by taking advantage of the loopholes in the tax system. As a result, income reported from intra-related transactions decreases. Hence, revenue collection also decreases. And so transfer pricing may really be called transfer mis-pricing! Please note, however, that decrease in the transfer price should not at all times be attributed to manipulation by the related parties. The Organisation for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines provide that the tax administrators should not automatically assume that associated enterprises have sought to manipulate their profits as they may truly experience difficulty in accurately determining a market price, in the absence of market forces or when adopting a particular commercial strategy. OECD TP Guidelines are the motherhood guidelines after which most, if not all, TP guidelines of different jurisdictions have been patterned. By way of addressing the Read More …