R.G. Manabat and Co.

January 6, 2020ITAD BIR RULING NO. 005-20Articles 5 (Permanent Establishment) and 8 (Business Profits) Philippines-United States of America tax treatyR.G. Manabat and Co.9th Floor, The KPMG Center6787 Ayala Avenue1226 Makati CityAttention: AAA_______________Gentlemen :This refers to the tax treaty relief application filed on June 11, 2014 requesting confirmation that income derived by Remington Outdoor Company, Inc. ("Remington") from the supply and delivery of firearms to the Armed Forces of the Philippines ("AFP") is exempt from income tax pursuant to the Convention between the Government of the Republic of the Philippines and the Government of the United States of America with Respect to Taxes on Income ("Philippines-United States tax treaty"). cSEDTCFACTSRemington is a foreign corporation organized and existing under the laws of the United States and a resident thereof based on its Restated Certificate of Incorporation and Certificate of Residence issued by the Internal Revenue Service of the United States. Remington is engaged in the design, manufacture and marketing of firearms, ammunition and related products for hunting, shooting sports, law enforcement and military markets. 1 It is...