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By: Mark Anthony P. Tamayo on November 21,2019 First of two parts The new guidelines on the establishment, operation, supervision and control of customs bonded warehouses (CBWs) was recently issued by the Department of Finance (DoF) and Bureau of Customs (BoC). Customs Administrative Order (CAO) No. 13-2019, which took effect...

By: Euney Marie J. Mata-Perez on November 14,2019 NEW rules on taxation of digitalized transactions are being proposed by OECD (Organization for Economic Co-operation and Development), and these rules will be game changing in international taxation. The power of taxation is exercised by each state. It is generally exercised over...

By: Euney Marie J. Mata-Perez on November 7,2019 The world is getting smaller. Cross-border and digital transactions are becoming an integral part of business and everyday life. Thus, a global approach to taxing digital transactions is essential; otherwise, the risk of different countries promulgating their own rules leading to double...

By: Euney Marie J. Mata-Perez on October 31,2019 So much has been written about the rationalization of tax incentives under the proposed Comprehensive Income Tax and Incentives Rationalization Act (Citira) or House Bill 4157. Thus, an understanding as to how the rationalization actual works is crucial. In the overall, Citira...

By: Euney Marie J. Mata-Perez on October 24,2019 In a joint statement released this week, 11 business groups expressed support for the “overall corporate income tax framework” under the proposed Corporate Income Tax and Incentives Rationalization Act (Citira) or House Bill 4157. Citira proposes, among others, the lowering of the...

By: Mark Anthony P. Tamayo on October 17,2019 MULTINATIONAL companies engaged in related party transactions normally set up their respective transfer pricing (TP) policies for the purpose of achieving their specific operating profit margin targets. It is common though that the target would materially fall outside of the arm’s-length range at...

By: Mark Anthony P. Tamayo on October 10,2019 The long awaited guidelines for transfer pricing (TP) examinations was recently issued by the Bureau of Internal Revenue (BIR) under Revenue Audit Memorandum Order (RAMO) 1-2019 dated Aug. 20, 2019. It is basically a manual of standardized procedures and techniques to be adopted...

By: Gerardo Maximo V. Francisco on October 3,2019 The jurisdiction of the National Labor Relations Commission (NLRC) is limited to cases or disputes where there is an employer-employee relationship between the parties. If no such employer-employee relationship exists, then the regular courts would have jurisdiction over the case or dispute....

By: Euney Marie J. Mata-Perez on September 26,2019 IN sale of shares outside the facilities of the stock exchange, gain is calculated by deducting cost from the higher of the selling price or the fair market value of the shares sold. Unlike valuation of land, our National Internal Revenue Code...