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Transfer Pricing Agreement

Transfer Pricing Agreement Template for Philippines

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Key Requirements PROMPT example:

Transfer Pricing Agreement

"I need a Transfer Pricing Agreement between our Philippine manufacturing subsidiary and Japanese parent company for automotive parts production, with specific focus on cost-plus pricing methodology and quarterly adjustments starting January 2025."

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Document background
The Transfer Pricing Agreement is essential for businesses operating in the Philippines through related entities, where intercompany transactions require structured pricing arrangements. This document is particularly crucial following the implementation of Philippine Revenue Regulations No. 2-2013 and subsequent updates, which strengthen transfer pricing documentation requirements and enforcement. The agreement serves as a formal framework for establishing arm's length pricing methodologies, ensuring compliance with both Philippine tax laws and international standards such as OECD guidelines. It is typically used when companies need to document and justify their internal pricing strategies, protect against tax adjustments, and demonstrate compliance with local and international transfer pricing regulations. The document includes comprehensive details on pricing methodologies, documentation requirements, compliance procedures, and review mechanisms, making it a critical tool for risk management and tax compliance in the Philippine context.
Suggested Sections

1. Parties: Identification of the related parties entering into the agreement, including their corporate details and relationships

2. Background: Context of the agreement, nature of the business relationship, and purpose of the transfer pricing arrangement

3. Definitions: Key terms used in the agreement, including technical transfer pricing terminology

4. Scope of Agreement: Details of transactions covered, products/services involved, and territories applicable

5. Transfer Pricing Methodology: Agreed pricing method(s) and justification for selection in accordance with Philippine regulations

6. Pricing Terms and Calculations: Specific pricing formulas, adjustments, and calculation methods

7. Documentation Requirements: Required records, reports, and documentation to maintain compliance with Philippine regulations

8. Term and Termination: Duration of the agreement and conditions for termination

9. Compliance and Review: Procedures for ensuring ongoing compliance and periodic review of the arrangement

10. Dispute Resolution: Procedures for resolving disagreements and handling tax authority inquiries

11. Confidentiality: Protection of sensitive pricing and business information

12. Governing Law: Application of Philippine law and relevant international guidelines

13. Execution: Signature blocks and execution formalities

Optional Sections

1. Force Majeure: Optional clause for extraordinary circumstances affecting pricing arrangements

2. Advance Pricing Arrangement: Include if parties seek advance agreement with tax authorities

3. Customs Valuation: Required if dealing with import/export of tangible goods

4. Intellectual Property Rights: Include when IP transfers or licenses are part of the pricing arrangement

5. Parent Company Guarantees: Include when additional financial security is required

6. Cost Sharing Provisions: Include for arrangements involving shared costs between parties

7. Currency and Exchange Rates: Include for international transactions with currency considerations

Suggested Schedules

1. Schedule A - Covered Transactions: Detailed list of all transactions covered by the agreement

2. Schedule B - Pricing Methodology Details: Technical details of pricing calculations and benchmarking studies

3. Schedule C - Documentation Templates: Required forms and formats for ongoing documentation

4. Schedule D - Functional Analysis: Analysis of functions, assets, and risks of each party

5. Schedule E - Comparable Analysis: Details of comparable transactions or companies used in pricing

6. Appendix 1 - Compliance Calendar: Timeline for documentation, reviews, and reporting requirements

7. Appendix 2 - Contact Details: Key personnel responsible for transfer pricing compliance

8. Appendix 3 - Group Structure Chart: Corporate structure showing relationships between parties

Authors

Alex Denne

Head of Growth (Open Source Law) @ 抖阴短视频 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions






































Clauses

































Relevant Industries

Manufacturing

Technology

Pharmaceutical

Automotive

Consumer Goods

Financial Services

Telecommunications

Energy and Resources

Professional Services

E-commerce

Healthcare

Chemical Industry

Software and IT Services

Retail and Distribution

Relevant Teams

Finance

Tax

Legal

Treasury

Compliance

Risk Management

Corporate Finance

International Tax

Transfer Pricing

Financial Planning and Analysis

Corporate Development

Accounting

Internal Audit

Relevant Roles

Tax Director

Chief Financial Officer

Transfer Pricing Manager

International Tax Manager

Finance Director

Compliance Officer

Tax Counsel

Financial Controller

Group Finance Manager

Treasury Manager

Legal Counsel

Risk Management Officer

Corporate Finance Manager

Tax Planning Manager

Global Tax Director

Industries








Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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