July 20, 1999
ITAD RULING NO. 009-99
RP-Netherlands Art. 21
J.A.C.A. Overgaauw
Director for International Tax Policy and Legislation
Ministry of Finance
The Netherlands
S i r :
This refers to your letter — IFZ99/87 M dated January 26, 1999 informing us on the guidelines/procedure on how residents of the Philippines can claim refund of Dutch dividend tax, and the introduction of euro currency in your country. However, as mentioned in your letter dated January 26, 1999, the said new euro currency may affect Art. 21, Paragraph 1 (b)(ii) of the RP-Netherlands Tax Convention, which states that:
"xxx xxx xxx
any remuneration for personal services performed in the first-mentioned State in an amount not in excess of 5,000 guilders or the equivalent in Philippine currency, as the case may be, for any taxable year. cdtai
xxx xxx xxx"
You suggested that in the said Article, guilder can be read as euro taking into account the exchange rate of the euro vis a vis the guilder. We propose, however, that a protocol be made on the said change.
In a previous letter - IFZ98/968 U you requested information on...
