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June 3, 2019ITAD BIR RULING NO. 009-19Articles 5 (Permanent Establishment) and 8 (Business Profits) Philippines-United States of America tax treatySycip Gorres Velayo and Co.6760 Ayala Avenue1226 Makati CityAttention: AAA__________Gentlemen :This refers to your tax treaty relief application filed on July 15, 2013 requesting confirmation that rentals paid by Air Drilling Associates Pte. Ltd. Philippine Branch ("Air Drilling SG-Philippine Branch") to Air Drilling Associates, Inc. ("Air Drilling US") are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United States of America with Respect to Taxes on Income ("Philippines-United States tax treaty").FACTS:Air Drilling US is a corporation organized and existing under the laws of the United States and a resident thereof based on its amended Articles of Incorporation and Certificate of Residence issued by the Internal Revenue Service. Air Drilling US is engaged in providing air, foam, and aerated fluid drilling services to petroleum and geothermal industries. 1 It is not registered as a corporation or partnership in the Philippines based on the...