October 22, 2018
ITAD BIR RULING NO. 101-18
Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-
United Kingdom of Great Britain and Northern Ireland tax treaty
United Coconut Planters Bank
UCPB Corporate Offices
7909 Makati Avenue
1200 Makati City
Attention: AAA
_______________
Gentlemen :
This refers to your tax treaty relief application filed on November 25, 2013 requesting confirmation that service fees paid by United Coconut Planters Bank ("UCPB") to Standard Chartered Bank ("Standard Chartered") 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").
It is represented that Standard Chartered is a corporation organized and existing under the laws of the United Kingdom and a resident thereof based on its Charter, By-Laws and Rules and its Certificate of Residence issued by Her Majesty's Revenue and Customs of the United Kingdom; that the object of Standard Chartered is to carry...
