The tale of transfer pricing in the Philippines

“Tale as old as time” — this now-famous beginning lyric from “Beauty and the Beast” can also applied to the authority of the commissioner of the Bureau of Internal Revenue (BIR) to review, allocate and distribute the income and deductions of related-party transactions, both cross-border and domestic. This include intra-firm transactions between related parties to determine the appropriate revenue and taxable income. Few people would know that this authority is now 81 years old; it was introduced on June 15, 1939 under Section 44 (now Section 50) of Commonwealth Act 466 or the “National Internal Revenue Code.”

Let us recount the notable events and facts on this authority’s implementation and evolution.