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October 23, 2018ITAD BIR RULING NO. 110-18Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-Thailand Tax TreatySumisetsu Philippines, Inc.8th Floor G.C. Corporate Plaza150 Legaspi Street, Legaspi Village1229 Makati CityAttention: AAA_______________Gentlemen :This refers to your tax treaty relief application filed on October 23, 2012 requesting confirmation that payments made to Thai Semcon Company, Limited ("Thai Semcon") by Sumisetsu Philippines, Inc. ("Sumisetsu") are not subject to Philippine income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the Kingdom of Thailand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Thailand tax treaty").It is represented that Thai Semcon is a corporation organized and existing under the laws of Thailand and a resident thereof for tax purposes based on its amended Articles of Association and the Certificate of Residence issued by the Revenue Department of Thailand; that Thai Semcon is engaged in electrical design and installation, communication design and installation, mechanical design and installation, and plant and machinery installation; that...