By Journal Online

Copyright journal

The Bureau of Internal Revenue (BIR), under the leadership of Commissioner Romeo D. Lumagui, Jr., conducted a Public Consultation on August 28, 2025 at the BIR National Office in Quezon City to present and discuss the draft Revenue Regulations (RR) to implement the Advance Pricing Agreement (APA) Program.

The event was attended by representatives from multi-sectoral groups, large taxpayers, tax practitioners, and other concerned stakeholders.

The APA Program is designed to allow taxpayers and the BIR to agree in advance on the appropriate transfer pricing methodology for related party transactions, thus minimizing transfer pricing disputes and reducing the risk of double taxation. The draft RR, which outlines the requirements, guidelines, and procedures for the APA Program, was presented by Chief Robbie M. Bañaga of the International Tax Affairs Division (ITAD).

In her presentation, Chief Bañaga highlighted the benefits of the APA Program, such as preventing prolonged transfer pricing audits; ensuring consistency with the arm’s length principle; and fostering trust between taxpayers and tax administration authorities.

Commissioner Lumagui likewise emphasized the significance of the APA Program in ensuring fairness in the Philippine tax system. “We want to provide certainty to businesses while at the same time protecting the government’s revenue base. The APA Program is not only a tool to prevent disputes but also a mechanism to build confidence between the BIR and taxpayers”, he said.

The Commissioner further assured that the BIR remains committed to aligning with the global best practices. “The Philippines is ready to join the international community in advancing effective transfer pricing administration. By implementing APAs, we are sending a clear message that our tax system is modern, transparent, and business-friendly, without compromising our mandate to collect the right taxes”, Commissioner Lumagui added.

During the Open Forum, the attendees raised their questions and provided feedback on the proposed regulations, particularly on the processes of pre-filing, application, negotiation, and compliance monitoring. BIR officials assured the attendees that the comments and suggestions gathered during the session would be evaluated and considered in the finalization of the Revenue Regulations.

The issuance of the final RR on APA is expected to institutionalize a structured mechanism for resolving complex transfer pricing issues. This initiative supports the government’s broader efforts to improve tax compliance, attract investments, and strengthen the country’s position in the global business landscape.