October 22, 2018
ITAD BIR RULING NO. 098-18
Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-
United Kingdom of Great Britain and Northern Ireland tax treaty
Ortiz and Dela Cruz Law Offices
Unit 506, Taipan Place
F. Ortigas Jr. Road
Ortigas Center
1605 Pasig City
Attention: AAA
BBB
CCC
Gentlemen :
This refers to your tax treaty relief application filed on October 6, 2017 requesting confirmation that service fees paid by Occidental Data Corporation ("Occidental") to Aperta Ltd. ("Aperta") (formerly Macrocom (181) Ltd.) are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains ("Philippines-United Kingdom tax treaty"). HCDAcE
FACTS
Aperta is a corporation organized and existing under the laws of the United Kingdom and a resident thereof based on its amended Articles of Association, and Certificate of Incorporation of a Private Limited Company issued by the Registrar of Companies of Scotland, and Certificate of Residence issued by...
