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October 22, 2018ITAD BIR RULING NO. 095-18Article 13 (Gains from the Alienation of Property) Philippines-Netherlands tax treatyIsla Lipana and Co.29th Floor, Philamlife Tower8767 Paseo de Roxas1226 Makati CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on December 22, 2015 requesting confirmation that capital gains derived by Asia Outsourcing Netherlands B.V. ("Asia Outsourcing") from the redemption of shares of stock in Asia Outsourcing Philippines Holdings, Inc. ("Asia Outsourcing Philippines") are exempt from income tax pursuant to the Convention between the Kingdom of the Netherlands and the Republic of the Philippines for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Netherlands tax treaty"). cSIHCAFACTSAsia Outsourcing is a foreign corporation organized and existing under the laws of the Netherlands and a resident thereof based on its Deed of Incorporation and Certificate of Residence issued by the Tax Administration Office of Arnhem in the Netherlands. Its objects are to incorporate, participate, manage, supervise, and finance businesses and companies, among others. Asia Outsourcing is not registered as a...