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October 19, 2018ITAD BIR RULING NO. 092-18Article 13 (Capital Gains) Philippines-Korea tax treatyAAA_______________ Dear AAA :This refers to your tax treaty relief application filed on March 30, 2015 requesting confirmation that capital gains derived by BBB from the sale of his shares of stock in JNE Philippines, Inc. ("JNE Philippines") to JNE Company Ltd., Inc. ("JNE") are exempt from capital gains tax pursuant to the Convention between the Republic of the Philippines and the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Korea tax treaty"). DCATHSFACTSBBB is a resident of Korea based on a certification issued by the Incheon Metropolitan City of Korea. The name BBB is not a registered business name in the Philippines based on a certification issued by the Department of Trade of Industry. On the other hand, JNE Philippines is a domestic corporation engaged in subcontracting several processes for manufacturing flexible flat cable products including plating, cutting, assembly and outgoing inspection.Based on JNE Philippines' 2014 General Information Sheet...