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January 15, 2019ITAD BIR RULING NO. 003-19Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-Singapore tax treatyAAA_______________________________________________________________Dear AAA :This refers to your tax treaty relief application filed on June 16, 2017, on behalf of Rapiscan Systems Pte. Ltd. ("Rapiscan"), requesting confirmation that income derived by Rapiscan from Philippine Ports Authority ("PPA") is exempt from income tax pursuant to the Convention between the Republic of the Philippines and the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Singapore tax treaty"). It is represented that Rapiscan is a foreign corporation organized and existing under the laws of Singapore and a resident thereof based on its Memorandum and Articles of Association and Certificate of Residence issued by the Inland Revenue Authority of Singapore; that the objects for which Rapiscan is established are to procure, manufacture, sell, test, install and commission, maintain and service security x-ray equipment, security metal detectors, including x-ray scanners, metal detecting equipment, explosives and narcotics detection equipment, auxiliary equipment peripheral or collateral...