October 23, 2018
ITAD BIR RULING NO. 113-18
Article 21 (Teachers) Philippines-
United Kingdom of Great Britain and Northern Ireland tax treaty
International School Manila, Inc.
University Parkway
Fort Bonifacio
1634 Taguig City
Attention: AAA
_______________
Gentlemen :
This refers to your tax treaty relief applications filed on November 13, 2012 requesting confirmation that remuneration paid by International School Manila, Inc. ("International School") to BBB and CCC is exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains ("Philippines-United Kingdom tax treaty").
FACTS
It is represented that BBB and CCC are British citizens and residents of the United Kingdom based on their passports and Certificates of Residence issued by Her Majesty's Revenue and Customs; that their names are not registered business names in the Philippines based on a certification issued by the Department of Trade and Industry; that they have Overseas Hire Contracts with International School where...
