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October 19, 2018ITAD BIR RULING NO. 091-18Articles 5 and 7 Philippines-Japan tax treaty,as amendedF. Tech R&D Philippines, Inc.F. Tech Annex Building123 North Avenue, Laguna Technopark4024 Biñan, LagunaAttention: AAA_______________Gentlemen :This refers to your tax treaty relief applications filed on July 16, 2015 and June 9, 2016 requesting confirmation that license fee for software paid by F. Tech R&D Philippines, Inc. ("F. Tech Philippines") to Delight Company Ltd. ("Delight") 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"). 1 SaIHDAIt is represented that Delight is a corporation organized and existing under the laws of Japan and a resident thereof based on its Articles of Incorporation and Certificate of Residence issued by the Kawasakinishi Tax Office in Japan; that Delight is engaged in importing, exporting, selling, purchasing, leasing, and licensing of computer programs, in providing consultancy services relating to computer programs, and in conducting research, development, selling, and purchasing...