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October 22, 2018ITAD BIR RULING NO. 105-18Article 21 (Teachers) Philippines-United Kingdom of Great Britain and Northern Ireland tax treatyInternational School ManilaUniversity ParkwayFort Bonifacio1634 Taguig CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief applications filed on September 23, 2014 and October 23, 2014 requesting confirmation that remuneration paid by International School Manila, Inc. ("International School") to BBB, CCC and DDD (collectively, "the teachers") 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").FACTSIt is represented that the above teachers are citizens and residents of the United Kingdom based on their passports and Certificates of Residence issued by Her Majesty's Revenue and Customs; that the names of those teachers are not registered business names in the Philippines based on a certification issued by the Department of Trade and Industry; that...