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October 23, 2018ITAD BIR RULING NO. 106-18Articles 5 (Permanent Establishment), 7 (Business Profits) and 15 (Dependent Personal Services) Philippines-China tax treatySycip Gorres Velayo and Co.6760 Ayala Avenue1226 Makati CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on April 27, 2012 requesting confirmation that service fees paid by Philippine Associated Smelting and Refining Corporation ("PASAR") to China Nerin Engineering Company Ltd. ("China Nerin") and remuneration paid by China Nerin to its employees are 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"). HTcADCFACTSChina Nerin is a foreign corporation organized and existing under the laws of China and a resident thereof based on its amended Articles of Association and the Business License issued by the Administration for Industry and Commerce of Jiangxi in China and the Certificates of Tax Registration issued by the Local Taxation Bureau...