Revenue Regulations No.2-2013 on Transfer Pricing Guidelines.

The Regulation defines the transfer pricing as the pricing of cross-border, intra- firm transactions between related parties or associated enterprises. The objective of this Regulation are implementing the authority of the Commissioner of Internal Revenue (“Commissioner”) to review controlled transactions among associated enterprises, prescribing guidelines in determining the appropriate revenues and taxable income of the parties in the controlled transaction, requiring the maintenance or safekeeping of the documents necessary for the taxpayer. These Regulations seek to provide guidelines in applying the Arm's length principle for cross- border and domestic transactions between associated enterprises. This Regulation consists of 17 Sections and refers to the issues of authority of the Commissioner to allocated income and deduction, Arm's length principle, comparability analysis, identification of the party, pricing methodologies and documentation.