October 23, 2018
ITAD BIR RULING NO. 111-18
Articles 5 (Permanent Establishment) and 7 (Business Profits) Philippines-
Singapore tax treaty
IdeasXMachina Advertising, Inc.
Ground Floor, Frankfurt Building
146 Pasig Boulevard
1600 Pasig City
Attention: AAA
Gentlemen :
This refers to your tax treaty relief application filed on June 30, 2016 requesting confirmation that commission paid by IdeasXMachina Advertising, Inc. ("IdeasXMachina") to Delphys Hakuhodo International Pte. Ltd. ("Delphys") is exempt from income tax pursuant to the Convention between the Republic of the Philippines and the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income ("Philippines-Singapore tax treaty").
FACTS
Delphys is a corporation organized and existing under the laws of Singapore and a resident thereof based on its Memorandum and Articles of Association and Certificate of Residence issued by the Inland Revenue Authority of Singapore. Delphys is engaged in advertising activities. 1 It is not registered as a corporation or partnership in the Philippines based on the Certificate of Non-Registration of Company issued by the Securities and Exchange Commission. On the other hand, IdeasXMachina is a domestic...
