n\a

May 31, 2019ITAD BIR RULING NO. 008-19Articles 5 (Permanent Establishment) and 7 (Business Profits)Philippines-Indonesia tax treatyAAA_____________________________________________ Madam :This refers to your tax treaty relief application filed on December 10, 2018 requesting confirmation that income payments made by Philippine National Railways ("PNR") to PT Industri Kereta Api (Persero) ("PT Inka") are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Indonesia tax treaty").FACTSPT Inka is a corporation organized and existing under the laws of Indonesia and a resident thereof based on its amended Articles of Association and Certificate of Taxpayer Residency issued by the Directorate General of Taxes of Indonesia. The business purpose of PT Inka is to implement and support the Indonesian government's programs and policies in the field of economics and national development, particularly in railways and the transportation industries, and to optimize utilization of resources to produce high quality...