Philippines: Guidelines and procedures for requesting MAP

Taxpayers requesting mutual agreement procedure (MAP) assistance from the Competent Authority (CA)

Guidelines and procedures

The Bureau of Internal Revenue (BIR) issued Revenue Regulations No. 10-2022 that provide guidelines and procedures for taxpayers requesting mutual agreement procedure (MAP) assistance from the Competent Authority (CA) for the Philippines.

  • The regulations outline the procedures for initiating a MAP request and specific information and documentation that a taxpayer is required to submit, including the steps involved, associated cost, and timeline.
  • The regulations provide that the Commissioner of Internal Revenue (CIR) is designated as the CA for the Philippines. When it is not possible for the CIR to deal directly with MAP cases, the CIR will delegate its functions and powers to other competent officials of the BIR via a Revenue Delegated Authority Order (RDAO).
  • The regulations also enumerate sample scenarios that necessitate MAP assistance—typically attribution of profits and transfer pricing adjustments. 

KPMG observation

A total of 43 income tax treaties have been concluded by the Philippines, most of which have a MAP provision. Considering recent developments in the tax laws and the current and future trends of remote working arrangements, disputes between taxpayers and tax authorities are likely to increase. The new MAP guidelines may encourage taxpayers to use MAP as an avenue to avoid double taxation.

Read an October 2022 report prepared by the KPMG member firm in the Philippines


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