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October 18, 2018ITAD BIR RULING NO. 088-18Article 13 Philippines-Japan tax treaty,as amendedDe Guzman, Rafal and Sansarona Law and ConsultancyJipang BuildingRoxas Boulevard corner Sen. Gil Puyat Avenue1302 Pasay CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on August 11, 2017 requesting confirmation that capital gains derived by Kyocera Crystal Device Corporation ("Kyocera Crystal") from the transfer of its shares of stock in Kyocera Crystal Device Philippines, Inc. ("Kyocera Crystal Philippines") (originally KSS Philippines, Inc., then Kyocera Kinseki Philippines, Inc.) to Kyocera Corporation ("Kyocera") are exempt from income tax pursuant to the Convention between the Republic of the Philippines and Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Japan tax treaty"), as amended. IAcTaCFACTSKyocera Crystal is a foreign corporation organized and existing under the laws of Japan and a resident thereof based on its amended Articles of Incorporation (AOI) and Certificate of Residence issued by the Murayama Tax Office in Japan. Kyocera Crystal is engaged in manufacturing and selling crystal oscillators, application devices...