Isla Lipana & Co.

February 7, 2020ITAD BIR RULING NO. 017-20Article 10 (7),Philippines-Netherlands tax treatyIsla Lipana & Co.29th Floor, Philamlife Tower8767 Paseo de Roxas1226 Makati CityAttention: AAA________________Gentlemen :This refers to your tax treaty relief application filed on May 4, 2017 requesting confirmation that profits remitted to Quezon Power, Inc. ("Quezon Power-Netherlands") by Quezon Power, Inc.-Philippine Branch ("Quezon Power-Philippines") are subject to income tax at the preferential rate of 10 percent pursuant to the Convention between the Republic of the Philippines and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Netherlands tax treaty"). HTcADCIt is represented that Quezon Power-Netherlands is foreign corporation organized and existing under the laws of the Netherlands and a resident thereof based on its Certificate of Residence issued by the Tax Administration Office of Rotterdam in the Netherlands; that Quezon Power-Netherlands is licensed by the Securities and Exchange Commission to establish a branch office in the Philippines; that the primary purpose of the branch office is to develop, implement, design, engineer,...