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August 10, 1999ITAD RULING NO. 017-99RP-UK-Art. 12RP-Netherlands-Art. 13RP-Germany-Art. 13000-00G.K. Goh Securities (Phils.), Inc.36/F C-C Rufino Plaza Tower,Ayala Avenue, Makati CityAttention: Mr. Isidro R. SantosVice PresidentGentlemen :This refers to your letter dated April 26, 1999, requesting confirmation of your opinion that sale of shares of stock by your non-resident foreign clients, particularly residents of United Kingdom (UK), Netherlands and Germany, are exempt from the stock transaction tax, pursuant to the RP tax treaties with UK, Netherlands and Germany. prcdIn reply, please be informed that Article 12 of the RP-UK Tax Treaty provides as follows:"Article 12Gains from the Alienation of Property1. Capital gains from the alienation of immovable property, as defined in paragraph (2) of Article 6, may be taxed in the Contracting State in which such property is situated.2. Capital gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting...