Heavy Transfer Pricing tax fines take effect

Jonathan Hore
Jonathan Hore

As I write this article, multi-national enterprises (MNEs) who file income tax returns for periods ending after July 1, 2019 are required to file such returns together with detailed transfer pricing (TP) documentation.

Whilst transfer pricing legislation took effect on July 1, 2019, it could only be implemented upon publication of the TP regulations on July 12, 2019, which stipulated how MNEs would comply with the new law.

Two tier tax penalties of P500, 000 and 200% of underpaid tax await MNEs which do not comply with the stipulations of the TP regulations and such penalties are already effective.

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