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October 22, 2018ITAD BIR RULING NO. 099-18Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-Singapore tax treatyPunongbayan and Araullo20th Floor, Tower 1The Enterprise Center6766 Ayala Avenue1200 Makati CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on November 27, 2015 requesting confirmation that software payments made by Del Monte Philippines, Inc. ("Del Monte") to Workflow Management and Document Consulting Asia Pte. Ltd. ("Workflow") are exempt from income tax pursuant to the Convention between the Republic of the Philippines and the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Singapore tax treaty"). CDHSacFACTSWorkflow is a corporation organized and existing under the laws of Singapore and a resident thereof based on its Memorandum and Articles of Association, and Business Profile issued by the Accounting and Corporate Regulatory Authority of Singapore, and Certificate of Residence issued by the Inland Revenue Authority of Singapore. Workflow is engaged in software development and programming activities and in providing related consultancy services. It is not registered as...