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October 22, 2018ITAD BIR RULING NO. 098-18Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-United Kingdom of Great Britain and Northern Ireland tax treatyOrtiz and Dela Cruz Law OfficesUnit 506, Taipan PlaceF. Ortigas Jr. RoadOrtigas Center1605 Pasig CityAttention: AAABBBCCCGentlemen :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"). HCDAcEFACTSAperta 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...