The Philippines Bureau of Internal Revenue (BIR) has issued Revenue Regulations No. 10-2022, which prescribe the guidelines and procedures for requesting Mutual Agreement Procedure (MAP) Assistance in the Philippines. The regulations outline the procedures for initiating a MAP request and the specific information and documentation that a taxpayer is required to submit in support of the request. Guidance is also provided on the implementation of a MAP agreement that has been reached. As specified in the regulations, typical examples of taxation not in accordance with a tax treaty that would necessitate MAP assistance include: The withholding tax rate imposed on...