July 8, 2019
REVENUE MEMORANDUM ORDER NO. 051-19
| SUBJECT | : | Guidelines and Procedures for the Processing and Issuance of Tax Residency Certificate |
| TO | : | All Internal Revenue Officers and Others Concerned |
I. OBJECTIVES
The International Tax Affairs Division (ITAD) of the Bureau of Internal Revenue is authorized to process the issuance of a Tax Residency Certificate (TRC). The TRC is secured by Philippine residents deriving income from sources within the jurisdiction of a Contracting State intending to avail the preferential tax treatment under the effective tax treaties of the Philippines.
Apart from eliminating or avoiding the effects of double taxation with respect to taxes on income and on capital, thereby encouraging foreign trade and investment, Contracting States conclude a tax treaty to avoid the risks of double non-taxation. This is done by allocating taxing rights between the Contracting States and ensuring that an income is not left untaxed through schemes resorted to by taxpayers who seek to obtain unintended treaty benefits.
In granting treaty benefits, it must be established and made clear that only residents of a Contracting State who...
