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August 16, 1999ITAD RULING NO. 018-99Art. 14, RP-JapanArt. 14, RP-KoreaNNA Philippines Co. Inc.Unit 1814, Cityland Herrera Tower98 Herrera cor. Valero Sts.Makati CityAttention.: Ms. Miriam E. LeccionesExecutive SecretaryGentlemen :This refers to your letter dated April 26,1999, requesting for a ruling on the correct tax rate applicable to a Japanese national and a Japan-born Korean who:1. has temporarily entered the Philippines without a visa under Executive Order No. 408 and rendered professional or skilled services to a domestic multinational company for a fee;2. has secured an Alien Employment Permit from the Department of Labor and Employment and has been present in the Philippines for an aggregate period of less than 180 days; likewise, the correct tax rate, if they are present in the Philippines for an aggregate period exceeding 180 days; and LexLib3. has secured both an Alien Employment Permit from the Department of Labor and Employment and 9 g Visa from the Bureau of Immigration and Deportation.In reply, please be informed as follows:1. Article 14 (1) of the RP-Japan Tax Treaty provides, viz:"Article 14"1. Income derived...