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October 22, 2018ITAD BIR RULING NO. 096-18Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-Thailand tax treatyCesar C. Cruz and Partners Law Offices3001 BPI-Philam Life Makati6811 Ayala Avenue1227 Makati CityAttention: AAAGentlemen :This refers to your tax treaty relief application filed on September 14, 2016 requesting confirmation that service fees paid by Atlas Fertilizer Corporation ("Atlas") to TTCL Public Company Ltd. ("TTCL") are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the Kingdom of Thailand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Thailand tax treaty"). CHcETAFACTSTTCL is a corporation organized and existing under the laws of Thailand and a resident thereof based on its Articles of Association and the Certificate issued by the Ministry of Commerce of Thailand and the Income Tax Payment Certificate issued by the Revenue Department of Thailand. TTCL is a publicly listed company in Thailand, and a joint venture company between Toyo Engineering Corporation of Japan and Italian-Thai...