n\a

October 22, 2018ITAD BIR RULING NO. 102-18Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-France tax treatyZambrano and Gruba Law Offices27th Floor, 88 Corporate Center141 Sedeño Street, Salcedo Village1227 Makati CityAttention: AAAGentlemen :This refers to your tax treaty relief application filed on January 11, 2016 requesting confirmation that service fees paid by Globe Telecom, Inc. ("Globe") to Sofrecom, S.A. ("Sofrecom") are exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-France tax treaty"). 1 FACTSSofrecom is a corporation organized and existing under the laws of France and a resident thereof based on its Articles of Association and Certificate of Residence issued by the Direction Generale des Finances Publiques of France. Sofrecom is engaged in carrying out technical and financial studies, consultations, and operations relating to telecommunications. It is not registered as a corporation or partnership in the Philippines based on the Certification...