August 16, 1999
ITAD RULING NO. 018-99
Art. 14, RP-Japan
Art. 14, RP-Korea
NNA Philippines Co. Inc.
Unit 1814, Cityland Herrera Tower
98 Herrera cor. Valero Sts.
Makati City
Attention.: Ms. Miriam E. Lecciones
Executive Secretary
Gentlemen :
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 LexLib
3. 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...
