November 19, 2018
ITAD BIR RULING NO. 118-18
Article 10 (Dividends), Philippines-
Singapore tax treaty
Navarro Amper and Co.
19th Floor, Net Lima Plaza
5th Avenue corner 26th Street
Bonifacio Global City
1634 Taguig City
Attention: AAA
_______________
Gentlemen :
This refers to your tax treaty relief application filed on December 21, 2012 requesting confirmation that cumulative dividends paid by SteelAsia Manufacturing Corporation ("SteelAsia") (formerly Tempcore Steel Corporation) to NatSteel Asia Pte. Ltd. ("NatSteel") (formerly NatSteel AsiaSteel Pte. Ltd.) upon the redemption of SteelAsia's preferred shares are subject to income tax at the rate of 15% 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
NatSteel 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, the Business Profile issued by the Registrar of Companies and Businesses of Singapore, and Certificate of Residence issued by the Inland Revenue Authority of Singapore. NatSteel is engaged in...
