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October 22, 2018ITAD BIR RULING NO. 094-18Article 14 (Capital Gains) Philippines-India tax treatyIsla Lipana & Co.29th Floor, Philamlife Tower8767 Paseo de Roxas1226 Makati CityAttention: AAA________________BBB________________Gentlemen :This refers to your tax treaty relief application filed on May 2, 2014 requesting confirmation that capital gains derived by Aditya Birla Minacs Worldwide Ltd. ("Aditya India") from the sale of its shares of stock in Aditya Birla Minacs Philippines, Inc. ("Aditya Philippines") to Maple Bid Company Ltd. ("Maple UK") are exempt from capital gains tax pursuant to the Convention between the Philippines and India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-India tax treaty"). ScaCEHFACTSAditya India is a foreign corporation organized and existing under the laws of India and a resident thereof based on its Memorandum and Articles of Association and Certificate of Residence issued by the Office of the Commissioner of Income Tax of India. The main objects of Aditya India are to carry on and undertake the business of setting up and operating centers for sales...