On 23 January 2013, the Bureau of Internal Revenue (BIR) issued Revenue Regulations (RR) No. 2-2013 or the transfer pricing guidelines. The guidelines are largely based on the OECD arm's length methodologies as set out in the OECD Transfer Pricing Guidelines. The main points of the guidelines are summarized below: -   they apply to cross-border transactions and domestic transactions between associated enterprises; -   the arm's length principle (ALP) that is embodied in Philippines tax treaties is substantially identical to that contained in article 9(1) of the OECD Model Tax Convention; -   details are provided on how to apply...