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October 22, 2018ITAD BIR RULING NO. 104-18Article 20 (Teachers and Researchers) Philippines-China tax treatyInternational School Manila, Inc.University ParkwayFort Bonifacio1634 Taguig CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on November 20, 2012 requesting confirmation that remuneration paid by International School Manila, Inc. ("International School") to BBB is exempt from income tax pursuant to the Agreement between the Government of the Republic of the Philippines and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-China tax treaty").FACTSIt is represented that BBB is an Australian citizen and a resident of China based on her passport and Certificate of Residence issued by the Local Tax Bureau of Pudong in Shanghai Province under the State Administration of Taxation of China; that her name is not a registered business name in the Philippines based on a certification issued by the Department of Trade and Industry; that she has a Part-Time Teaching Employment with International School where she was contracted...