The Bureau of Internal Revenue (BIR) in Manila is planning to issue new transfer pricing regulations. In 2006, it produced a draft which included documentation requirements and a model advance pricing agreement (APA) mechanism. BIR Deputy Commissioner Nelson Aspe said the transfer pricing rules will make sure intra-company transactions are done at arm’s length. "There should be a threshold in selling to determine the right pricing. A lot of tax practitioners welcome this revenue regulation," he said.

Romulo Danao, tax and transfer pricing partner at Ernst & Young, told TP Week, said: “The BIR originally issued draft transfer pricing regulations in August 2006 which was submitted to the Department of Finance (DOF) for final review and approval. Unlike the previous statements on transfer pricing, the draft regulations provide for an APA mechanism and various documentation requirements, as well as a paragraph on thin capitalisation rules.