October 23, 2018
ITAD BIR RULING NO. 108-18
Article 13 (Gains from the Alienation of Property) Philippines-
Netherlands tax treaty
Buan & Temprosa Law Offices
Unit 1005 and 1006, Cityland Condominium 10, Tower 1
156 H.V. dela Costa Street
1226 Makati City
Attention: AAA
BBB
Gentlemen :
This refers to your tax treaty relief application filed on April 4, 2017 requesting confirmation that capital gains derived by Universal Music International Holding B.V. ("UMIH") (formerly, Universal International Holding B.V.) from the transfer of its shares of stock in MCA Music, Inc. ("MCA") to Universal International Music B.V. ("UIM") are exempt from capital gains tax pursuant to the Convention between the Kingdom of the Netherlands and the Republic of the Philippines for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Netherlands tax treaty"). HTcADC
It is represented that UMIH and UIM are corporations organized and existing under the laws of the Netherlands and residents thereof based on their amended Articles of Association and Certificates of Residence issued by the Arnhem Tax Office in the Netherlands; that UMIH and UIM are...
