Philippines Tax News

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Treaty between Germany and Philippines – details

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Treaty between Germany and Philippines signed

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Netherlands government council agrees to combat international tax avoidance

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Treaty between Philippines and Thailand signed

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Protocol to treaty between France and Philippines enters into force

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Transfer Pricing guidelines issued – details

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Treaty between Philippines and Turkey – details

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Treaty between Qatar and Philippines enters into force

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Treaty between Philippines and Turkey signed

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Treaty between Philippines and United Arab Emirates – details

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Treaty between Qatar and Philippines ratified

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Protocol to treaty between Philippines and Japan – details

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Treaty between Qatar and Philippines signed

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Protocol to treaty between Japan and Philippines enters into force

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Protocol to treaty between New Zealand and Philippines enters into force and details

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Consolidated regulations on taxation of disposals of shares of domestic companies held as capital assets

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Draft Circular clarifying taxability of businesses located in ECOZONE issued

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Amendments on guidelines for registration of securities borrowing transactions and tax treatment

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Guidelines on implementation of Improved Voluntary Assessment Program (IVAP) issued

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Protocol to treaty between Japan and Philippines signed

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Protocol to treaty between Japan and Philippines – negotiations

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Treaty between Japan and Philippines – negotiations

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Philippine ruling that guarantee fees are not interest under Philippines-Korea (Rep.) tax treaty

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Loans of listed securities proposed to be tax exempt

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The Court of Tax Appeals in Mirant (Philippines) Operations Corp. v. CIR, CTA Case No. 6382 (7 June 2005) confirmed that the filing of an application for tax treaty relief with the Bureau of Internal Revenue, and the subsequent issuance of an official ruling to confirm the application of a preferential tax rate under a Philippines treaty, are mandatory for the non-resident taxpayer who intends to avail of such a preferential rate on its Philippine-source income. The non-resident taxpayer cannot rely on rulings issued to other taxpayers, who may not actually be similarly situated, as basis for treaty relief

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Germany confirmed that negotiations for a new tax treaty with the Philippines are ongoing, although no scheduled negotiation dates have been released. Once signed and in force, the new treaty will replace the Germany-Philippines income and capital tax treaty of 22 July 1983.

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The corporate income tax rate will be increased from 32% to 35% for 2006, 2007, 2008 and the rate will be reduced to 30% s from 2009.

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