August 20, 2019
REVENUE AUDIT MEMORANDUM ORDER NO. 001-19
| SUBJECT | : | Transfer Pricing Audit Guidelines |
| TO | : | All Internal Revenue Officers and Others Concerned |
I. OBJECTIVE
The Transfer Pricing Audit Guidelines is intended to supplement Revenue Audit Memorandum Order (RAMO) No. 1-2000 (Updated Handbook on Audit Procedures and Techniques Volume 1) and RAMO No. 1-2008 (Computer Assisted Audit Tools and Techniques), and to provide standardized audit procedures and techniques in the conduct of audit of taxpayers with related party and/or intra-firm transactions in order to ensure quality audit.
II. PURPOSE
The Transfer Pricing Audit Guidelines provides a framework and guide for transfer pricing examinations. Every transfer pricing issue is unique, and teams should exercise their judgement on how to best apply this guide.
III. SCOPE
1. The Guidelines are applicable on controlled transactions including sale, purchase, transfer and utilization of tangible and intangible assets, provision of intra-group services, interest payments and capitalization among others, between related/associated parties, where at least one party is assessable or chargeable to tax in the Philippines.
2. The Guidelines are also applicable by analogy,...
