December 9, 2019
ITAD BIR RULING NO. 039-19
Article 22 of the Philippines-Japan tax treaty
Transnational Diversified Corporation
The Penthouse, Net Quad Building
4th Avenue corner 30th Street
E Square Crescent Park West
Bonifacio Global City, Taguig
Attention: AAA
_______________
Gentlemen :
This refers to your application for tax treaty relief dated June 17, 2013 requesting confirmation that guarantee fee to be paid by NYK Transnational Properties Corp. ("NTPC") and NYK-FIL Maritime E-Training, Inc. ("NETI") to Nippon Yusen Kabushiki Kaisha ("NYK") is tax exempt under The Convention between the Government of the Republic of the Philippines and the Government of Japan with respect to Taxes on Income, as further amended by the 2009 Protocol (Philippines-Japan tax treaty). HTcADC
It is represented that NYK is a foreign corporation organized and existing under the laws of Japan and a resident thereof based on the Certificate of Residence issued by the District Director of Kojimachi Tax Office in Tokyo, Japan; that it is engaged in the business marine transportation, land transportation, air transportation and loans to, guarantees for and investments in other businesses, among others; and that NYK is not...
