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October 22, 2018ITAD BIR RULING NO. 103-18Article 13 (Capital Gains) Philippines-Korea tax treatyVillaraza and Angangco LawCVC Law Center11th Avenue corner 39th StreetBonifacio TriangleBonifacio Global City1634 Taguig CityAttention: AAABBBCCCGentlemen :This refers to your tax treaty relief application filed on August 8, 2014 requesting confirmation that liquidating dividends paid by EWP Philippine Holdings Corporation ("EWP Philippines") to Korea East-West Power Company Ltd. ("Korea Power") are exempt from income tax pursuant to the Convention between the Republic of the Philippines and the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Korea tax treaty"). HTcADCFACTSKorea Power is a foreign corporation organized and existing under the laws of Korea and a resident thereof based on its amended Articles of Incorporation and Certificate of Residence issued by the Samseong District Tax Office in Korea. The primary purpose of Korea Power is to develop electric power resources, to generate electricity by operating power plants, and to engage in other necessary or related activities. It is not registered as a...