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RMO No. 63-99: Prescribes the adoption of arm’s length bargaining standard in the determination of taxable income on inter-company loans or advances

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Summary

RMO No. 63-99, issued August 13, 1999, sets guidelines on determining taxable income from inter-company loans or advances under Section 50 of the Tax Code, as amended.

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Key points

  1. Arm’s length bargaining standard. This standard is the ultimate test for finding the correct gross income and deductions.
  2. Enterprises covered. It applies between two or more enterprises under common control.

Who is affected

  • Enterprises under common control with inter-company loans or advances

Deadlines and effectivity

  • Issued August 13, 1999

Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.

Copies of BIR issuances are hosted here for reference. For the official version, check bir.gov.ph. Summaries by Tax Resources PH are not a substitute for the full text or professional advice.