Dec 7 Tax Training

True or false:

A company that has direct or indirect participation in the control, capital, and management of another company is considered to be a related party to the latter.

• True

• False

Which among the following are NOT considered as related parties:

• Joint ventures of the same 3rd party

• Companies with shared board directors

• A company and a post-employment benefit plan for the benefit of its employees

• Companies that are members of the same group

1. Which of the following could be required to be submitted during a tax audit: 

1. I. TP Audit Forms

2. II. TP Documentation

3. III. Other supporting documents (e.g., certified true copy of Advance Pricing Agreement, etc.)

• I and II only

• II and III only

• I and III only

• All of the above

True or false:

Newly incorporated companies that already have related-party transactions are not required to prepare a TP documentation within the first two (2) years after their incorporation.

• True

• False

The existence of an intra-group service is recognized if it provides:

I. Commercial value to the recipient

II. Economic benefit to the recipient

III. Incidental benefit to the members of the group

• I only

• II only

• I and II only

• I, II, and III

True or false:

Compensation and benefits of key management personnel are required to be disclosed in the BIR Form No. 1709 (RPT Form).

• True

• False

Which of the following statement/s is/are TRUE?

I. Taxpayers under audit shall submit the TP Audit Forms (Annexes) within 15 working days upon request.

II. For eFPS Filers, the BIR Form No. 1709 is required to be submitted within 15 days from statutory due date or actual filing, whichever is later.

III. TP documentation and other supporting documents are required to be submitted to the BIR within 30 calendar days upon receipt of request.

• I, II, and III

• II and III only

• I and II only

• II only

True or false:

Under the OECD BEPS 2.0 Pillar 2, multinational groups with consolidated revenue over EUR 750 million are subject to a minimum Effective Tax Rate of 12% on income arising in low-tax jurisdictions.

• True

• False

True or false:

The arm’s length interest rate is currently at 6%.

• True

• False

True or false:

The Amount B under Pillar 1 aims to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities, focusing on the needs of low-capacity countries.

• True

• False