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June 4, 2019ITAD BIR RULING NO. 012-19Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-Singapore tax treatyRubio and RubioLevel 3, Joy Nostalg Center17 ADB Avenue, Ortigas Center1605 Pasig CityAttention: AAAGentlemen :This refers to your tax treaty relief application filed on September 28, 2016 requesting confirmation that payments made by Exclusive Networks-PH, Inc. ("Exclusive Networks") (formerly Transition Systems Philippines Pte. Ltd.) to F5 Networks Singapore Pte. Ltd. ("F5 Networks") are 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"). FACTSF5 Networks 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. F5 Networks is engaged in the provision of technical support, sales, after sales and maintenance services for computer software, peripheral equipment and products, and training of personnel in the...