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October 22, 2018ITAD BIR RULING NO. 097-18Article 10 Philippines-Japan tax treaty,as amendedIsla Lipana & Co.29th Floor, Philamlife Tower8767 Paseo de Roxas1226 Makati CityAttention: AAA_______________BBB_______________CCC_______________DDD_______________Gentlemen :This refers to your tax treaty relief application filed on April 4, 2017 requesting confirmation that gains derived by Muramoto Industry Company Ltd. ("MIC") from the repurchase/buyback of a portion of its shares of stock in Muramoto Audio-Visual Philippines, Inc. ("MAPLE") are in the nature of capital gains and 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"), as amended. aTEAHcFACTSMIC is a foreign corporation organized and existing under the laws of Japan and a resident thereof based on its Articles of Association and Residence Certificate issued by the Suma Tax Office in Japan. The objects of MIC are to design, manufacture, and sell molds, and to process metal and resins. MIC is not registered as a corporation or partnership in the Philippines...