n\a

October 23, 2018ITAD BIR RULING NO. 112-18Article 8 (Shipping and Air Transport),Philippines-Singapore tax treatyStarline Shipping Agencies Phils., Inc.6th Floor GE Antonio BuildingTM Kalaw Street corner J. Bocobo Street1000 Ermita, ManilaAttention: AAA_______________Gentlemen :This refers to your application for tax treaty relief dated May 19, 2014 requesting confirmation that BLPL Singapore Pte. Ltd. ("BLPL") is subject to income tax at the rate of 1 1/2 percent on its Gross Philippine Billings 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").It is represented that BLPL is a foreign corporation organized and existing under the laws of Singapore and a resident thereof based on its amended Memorandum and Articles of Association and Certificate of Residence issued by the Inland Revenue Authority of Singapore; that BLPL's object is to establish, maintain and operate shipping and ancillary services; that it is not registered as a corporation or partnership in the Philippines as confirmed by...