Rmo 08-2017 PDF
Rmo 08-2017 PDF
Rmo 08-2017 PDF
SECTION 1. Background. —
The United Nations recognizes that the 'single most important factor
bearing on the compliance by nonresidents with domestic tax law is the use of
source withholding by the source State.' 1(2) Moreover, the UN states that the 'use
of final withholding taxes to collect tax from nonresidents is widespread and
recognized internationally as a mechanism to collect tax.' 2(3)
Towards this end, the Bureau of Internal Revenue (BIR), in its efforts to
improve the efficient administration of Philippine tax treaties, adopts the
self-assessment system and automatic withholding of taxes on income of
nonresidents deriving Dividend, Interest and Royalty from sources within the
Philippines at applicable tax treaty rates subject to post reporting validation.
SECTION 2. Objectives. —
This Order seeks to provide for the new procedures in claiming preferential
tax treaty benefits on dividend, interest and royalty income of nonresidents
pursuant to effective tax treaties of the Philippines, thereby amending for this
purpose, Revenue Memorandum Order (RMO) No. 72-2010 .
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The foregoing objectives are achieved through:
SECTION 3. Coverage. —
SECTION 4. Definition. —
Part I:
Part II:
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treaty being invoked;
3. For dividend income purposes, the CORTT Form shall be valid for
two (2) years from date of issuance. However, if a prescribed certificate of
residency of the country of residence is used, the date of validity of the latter
document will prevail over the two (2)-year period given. For interest and royalty
income purposes, the CORTT Form shall be valid per contract.
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6. The ITAD and Revenue District Office (RDO) No. 39 shall be in
charge of receiving and recording information stated in the CORTT.
7. Pertinent information from the CORTT Form and data collected from
1601-F and 1604-CF on availment of treaty rates and income payment made to
nonresidents, in general, shall be accumulated and monitored by ITAD and RDO
No. 39. Such data shall be used for conducting risk analysis, formulating policies,
developing the country's treaty negotiating positions and generating management
reports.
2. The withholding agent/income payor shall file BIR Form 1601-F and
BIR Form 1604-CF and shall pay the withholding taxes due in accordance with the
Tax Code and existing Revenue Issuances.
a) If the CORTT Form filed with ITAD and RDO No. 39 is used
for another dividend payment within its prescribed period of
validity; and
SECTION 7. Penalties. —
Nonresidents who already filed TTRAs with the BIR on dividend, interest
and royalty income prior to the effectivity of this Order will be allowed to use the
tax treaty rates invoked based on effective tax treaties of the Philippines with other
countries. However, the same will be subjected to compliance check.
For existing TTRAs with the BIR with supporting documents, ITAD will
use the submitted information in creating a database for purposes of tax treaty
relief availment. If the requisite certificate of residency is not available in the
submitted documents, the withholding agents/income payor will be requested to
submit the same.
SECTION 10. Effectivity. — This Order shall take effect after 90 days
upon signing to afford nonresident income earners time to secure the required
CORTT Form or prescribed certificate of residency from their respective countries
of residence. aDSIHc
ANNEX A
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Country Country Dividend Rates
Code
Australia AU 15% where relief, either by way of credit as 25% in any other
described in paragraph 2 of Article 24 or relief case
by way credit as described in the second
sentence of paragraph 4 of Article 24, is
given to the beneficial owner of the dividends
Austria AT 10% dividends if the beneficial owner is a 25% in all other
company which holds directly at least 10 per cases
cent either of the voting shares of the
company paying the dividends or of the total
shares issued by that company during the
period of six months immediately preceding
the date of payments of the dividends
Bahrain BH 10% if the beneficial owner is a company 15%
(excluding partnerships) which holds directly
at least ten per cent (10%) of the capital of
the paying company
Bangladesh BD 10% if the beneficial owner is a company 15% in all other
(excluding partnerships) which holds directly cases
at least 25 per cent of the capital of the
paying company
Belgium BE 10% if the beneficial owner is a company 15% in all other
which holds directly at least 10 per cent of the cases
capital of the company paying the dividends
Brazil BR 15% if the recipient is a company including a 25% in all other
partnership cases
Canada CA 15% paid to a company which is a resident of 25% in all other
Canada which controls at least 10 per cent of cases
the voting power of the company paying the
dividend
China CN 10% if the beneficial owner is a company 15% in all other
which holds directly at least 10 per cent of the cases
capital of the company paying the dividends
Czech CZ 10% if the beneficial owner is a company 15% in all other
which holds directly at least 10 per cent of the cases
capital of the company paying the dividends
Denmark DK 10% if the beneficial owner is a company 15% in all other
(other than a partnership) which holds directly cases
at least 25 per cent of the capital of the
company paying the dividends
Finland FI 15% if the recipient is
a company (excluding
partnership) owning
at least 10 per cent of
the voting stock of the
company paying the
dividends.
France FR 10% if the recipient is a company (excluding 15% in all other
partnership) which holds directly at least 10 cases
per cent of the voting shares of the company
paying the dividends
Germany DE 5% if the beneficial owner is a company 10% if the beneficial 15% in all other
(other than a partnership) which holds directly is a company (other cases
at least 70 per cent of the capital of the than a partnership)
company paying the dividends which holds directly
at least 25 per cent of
the capital of the
company paying the
dividends
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Hungary HU 15% if the beneficial owner is a company 20% in all other
which holds directly at least 25 percent of the cases
capital of the paying company
India IN 15% if the beneficial owner is a company 20% in all other
which owns at least ten per cent of the shares cases
of the company paying the dividends
Indonesia ID 15% if the beneficial owner is a company 20% in all other
which holds directly at least 25 percent of the cases
capital of the paying company
Israel IL 10% if the beneficial owner is a company 15% in all other
(excluding partnership) which holds directly at cases
least 10 percent of the capital of the paying
company
Italy IT 15% if the recipient is the beneficial owner of
the dividends
Japan JP 10% if the beneficial owner is a company 15% in all other
which holds directly at least 10 per cent either cases
of the voting shares of the company paying
the dividends or of the total shares issued by
that company during the period of six months
immediately preceding the date of payment of
the dividends, or dividends paid by a
company, being a resident of the Philippines,
registered with the Board of Investments and
engaged in preferred pioneer areas of
investment under the investment incentives
laws of the Philippines to a resident of Japan,
who is the beneficial owner of the dividends
Korea KR 10% if the beneficial owner is a company 25% in all other
(other than a partnership) which holds directly cases
at least 25 per cent of the capital of the
company paying the dividends, or dividends
paid by a company, being a resident of the
Philippines, registered with the Board of
Investments and engaged in preferred
pioneer areas of investment under the
investment incentives laws of the Philippines
to a resident of Korea
Kuwait KW 10% if the beneficial owner is a company 15% in all other
(excluding partnership) which holds directly at cases
least 10 percent of the capital of the paying
company
Malaysia MY 15% if the recipient is a company 25% in all other
cases
Netherlands NL 10% if the recipient is a company the capital 15% in all other
of which is wholly or partly divided into shares cases
and which holds directly at least 10 per cent
of the capital of the company paying the
dividends
New Zealand NZ 15% if the beneficial owner is a company 25% in all other
cases
Nigeria NG 12.5% if the beneficial owner is a company 15% in all other
(excluding partnership) which holds directly at cases
least 10 percent of the capital of the paying
company
Norway NO 15% if the beneficial owner is a company 25% in all other
which controls directly or indirectly at least 10 cases
per cent of the voting power in the company
paying the dividends
Pakistan PK 15% if the beneficial owner is a company 25% in all other
(excluding partnership) which holds directly at cases
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least 25 per cent of the capital of the paying
company during the part of the paying
company's taxable year which precedes the
date of payment of the dividends and during
the whole of its prior taxable year, if any
Poland PL 10% if the beneficial owner is a company 15% in all other
(excluding partnerships) which holds directly cases
at least 25 per cent of the capital of the
paying company
Qatar QA 10% if the beneficial owner is a company 15% in all other
(excluding partnership) which holds directly at cases
least 10 percent of the capital of the paying
company
Romania RO 10% if the recipient is a company (excluding 15% in all other
partnership) and during the part of the paying cases
corporations taxable year which precedes the
date of payment of the dividends and during
the whole of its prior taxable year (if any), at
least 25 per cent of the outstanding shares of
the voting stock of the paying corporation was
owned by the recipient corporation
Russia RU 15% if the recipient is the beneficial owner of
the dividends
Singapore SG 15% if the recipient is a company (including 25% in all other
partnership) and during the part of the paying cases
company's taxable year which precedes the
date of payment of the dividend and during
the whole of its prior taxable year (if any), at
least 15 per cent of the outstanding shares of
the voting stock of the paying company was
owned by the recipient company
Spain ES 10% if the recipient is a corporation 15% in all other
(excluding partnership) which holds directly at cases
least 10 per cent of the voting shares of the
company paying the dividends
Sweden SE 10% if the beneficial owner is a company 15% in all other
(excluding partnerships) which holds directly cases
at least 25 per cent of the capital of the
paying company
Switzerland CH 10% if the beneficial owner is a company 15% in all other
(excluding partnerships) which holds directly cases
at least 10 per cent of the capital of the
paying company
Thailand TH 15% if the company paying the dividends is a 20% if the company
Philippine company or if the company paying paying the dividends
the dividends is a Thai company engaged in is a Thai company
an industrial undertaking not engaged in an
industrial undertaking
Turkey TR 10% if the beneficial owner is a company 15% in all other
(excluding partnership) which holds directly at cases
least 25 percent of the capital of the paying
company
United Arab AE 10% if the beneficial owner is a company 15% in all other
Emirates (excluding partnerships) which holds directly cases
at least 10 per cent of the capital of the
paying company
United GB 15% if the beneficial owner is a company 25% in all other
Kingdom of which controls directly or indirectly at least 10 cases
Great Britain per cent of the voting power in the company
and Northern paying the dividends
Ireland
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United US 20% when the recipient is a corporation, if 25%
States of during the part of the paying corporation's
America taxable year which precedes the date of
payment of the dividend and during the whole
of its prior taxable year (if any), at least 10
percent of the outstanding shares of the
voting stock of the paying corporation was
owned by the recipient corporation.
Vietnam VN 10% if the beneficial owner is a company 15% in all other
(excluding partnerships) which holds directly cases
at least 25 per cent of the capital of the
paying company
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the interest the tax so respect of public issues debenture or other similar obligation of
charge of bonds, debentures or the government of that Contracting
similar obligations and State or of a political subdivision or
paid by a company local authority thereof shall, provided
which is a resident of that the interest is beneficially owned
the Philippines to a by a resident of the other Contracting
resident of Finland State be taxable only in that other
State:
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Contracting States.
Hungary HU 15% if the recipient is Interest arising in a Contracting State
the beneficial owner of and paid to a resident of the other
the interest Contracting State shall be taxable only
in that other State, if the interest is
paid in respect of:
b) interest arising in a
Contracting State shall be
exempt from tax in that
Contracting State to the
extent approved by the
Government of that State
if it is derived and
beneficially owned by any
person [other than a
person referred to in
sub-paragraph (a)] who is
a resident of the other
Contracting State
provided that the
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transaction giving rise to
the debt-claim has been
approved in this regard
by the Government of the
first-mentioned
Contracting State.
Indonesia ID 15% if the recipient is 10% in respect of public Interest arising in a Contractin
the beneficial owner of issues of bonds, and paid to a resident of the other
the interest debentures or similar Contracting State shall be taxable only
obligations in that other State, if the interest is
paid in respect of:
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public issues of bonds,
debentures, or similar a) the payer of the interest is the
obligations and paid by Government of that Contracting
a resident of one State or a local authority thereof;
Contracting State to a or
resident of the other
Contracting State b) the interest is paid to the
Government of the other
Contracting State or local authority
thereof or any agency or
instrumentality (including a
financial institution) wholly owned
by that other Contracting State or
local authority thereof; or
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from that other State.
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Poland PL 10% Interest arising in a Contracting State
and paid to a resident of the other
Contracting State shall be taxable only
in that other State if the interest is paid
in respect of:
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the case of Romania and by the
Central Bank of the Philippines in
the case of the Philippines, or by
any other instrumentality as is
specified and agreed in lett
exchanged between the
Competent Authorities of the
Contracting States.
Russia RU 15% if the recipient is Interest paid by a Contracting State to
the beneficial owner of the government of the other State or a
the interest political subdivision or local authority
thereof shall be taxable only in that
other State.
Singapore SG 15% if the recipient is a) interest arising in a Contracting
the beneficial owner of State and paid to a resident of the
the interest other Contracting State shall be
taxable only in that other
Contracting State if it is paid in
respect of a loan made,
guaranteed or insured, or a credit
extended, guaranteed or insured,
by such institutions as are
specified and agreed in letters
exchanged between the competent
authorities of the Contracting
States; and
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(ii) in the case of the Philippines,
the Central Bank of the
Philippines.
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(ii) it arises in the Republic of the Philippines;
Philippines in
respect of public (ii) the Central Bank of the
issues of bonds, Philippines;
debentures or
similar obligations; (iii) the Development Bank of the
Philippines; and
Australia AU 15% where the royalties are paid by an 25% in all other cases
enterprise registered with the Philippine
Board of Investments and engaged in
preferred areas of activities
Austria AT 10% if the royalties are paid by a 15% if the recipient is the
company, which is a resident of the beneficial owner of the
Philippines registered with the Board of royalties
Investments and engaged in preferred
pioneer areas of investments under the
investment incentives laws of the
Philippines, to a resident of Austria,
who is the beneficial owner of the
royalties
Bahrain BH 10% in all other cases provided that the 15% if the beneficial owner of
recipient is the beneficial owner of the the royalties is a resident of
royalties the other Contracting State
and the royalties are arising
from the use of, or the right to
use, any copyright of literary,
artistic or scientific work
including cinematograph films
or tapes for television or
broadcasting
Bangladesh BD 15% if the beneficial owner of the
royalties is a resident of the other
Contracting State
Belgium BE 15% if the beneficial owner of the
royalties is a resident of the other
Contracting State
Brazil BR 15% shall only apply to royalties paid 25% in all other cases
by an enterprise registered with the provided that the recipient is
Philippine Board of Investment and the beneficial owner of the
engaged in preferred areas of activities royalties
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Canada CA 25% in the Philippines The lowest rate of Philippine
tax that may be imposed on
royalties of the same kind
paid in similar circumstances
to a resident of a third State
China CN 10% if the recipient is the beneficial 15% if the recipient is the
owner of the royalties and the royalties beneficial owner of the
are arising from the use of, or the right royalties and the royalties are
to use, any patent, trade mark, design arising from the use of, or the
or model, plan, secret formula or right to use, any copyright of
process, or from the use of, or the right literary, artistic or scientific
to use, industrial, commercial, or work including cinematograph
scientific equipment, or for information films or tapes for television or
concerning industrial, commercial or broadcasting
scientific experience
Czech CZ 10% if the beneficial owner of the 15% if the beneficial owner of
royalties is a resident of the other the royalties is a resident of
Contracting State and the royalties are the other Contracting State
arising from the use of, or the right to and the royalties are arising
use, any copyright of literary, artistic or from the use of, or the right to
scientific work, other than that use, any copyright of
mentioned in sub-paragraph (b), any cinematograph films, and
patent, trade mark, design or model, films or tapes for television or
plan, secret formula or process, or from radio broadcasting
the use of, or the right to use,
industrial, commercial or scientific
equipment, or for information
concerning industrial, commercial or
scientific experience
Denmark DK 15% if the recipient is the beneficial
owner of the royalties
Finland FI 15% where the royalties are paid by an 25% in all other cases
enterprise registered with and engaged
in preferred areas of activities, and also
royalties in respect of cinematographic
films or tapes for television or
broadcasting and royalties for the use
of, or the right to use, any copyright of
literary, artistic or scientific work
France FR 15% if the beneficial owner of the
royalties is a resident of the other
Contracting State
Germany DE 10% if the beneficial owner of the
royalties is a resident of the other
Contracting State
Hungary HU 15% if the recipient is the beneficial The lowest rate of Philippine
owner of the royalties tax that may, under similar
circumstances, be imposed
on royalties derived by a
resident of a third State
India IN 15% if the recipient is the beneficial
owner of the royalties and provided that
such royalties are payable by an
enterprise which is registered with the
Board of Investment
Indonesia ID 15% where the royalties are paid by an 25% in all other cases
enterprise registered with the Philippine
Board of Investments, and engaged in
preferred areas of activities as
determined by the said Board
Israel IL 15% if the recipient is the beneficial The lowest rate of Philippine
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owner of the royalties tax that may, under similar
circumstances, be imposed
on royalties derived by a
resident of a third State
Italy IT 15% if the recipient is the beneficial 25% in all other cases If the
owner of the royalties and where the Philippines
royalties are paid by an enterprise agrees to a
registered with the Philippine Board of lower rate of tax
Investments and engaged in preferred on royalties of
areas of activities and also royalties in the same kind
respect of cinematographic films or paid in similar
tapes for television or broadcasting circumstances
to a resident of
a third state,
then this lower
rate shall
likewise be
applied to
residents of Italy
Japan JP 10% in all other cases provided that the 15% if the recipient is the
recipient is the beneficial owner of the beneficial owner of the
royalties or if the royalties are paid by a royalties and the royalties are
company, which is a resident of the paid in respect of the use of
Philippines registered with the Board of or the right to use
Investments and engaged in preferred cinematograph films and films
pioneer areas of investments under the or tapes for radio or television
investment incentives laws of the broadcasting
Philippines, to a resident of Japan, who
is the beneficial owner of the royalties.
Korea KR 10% if the royalties are paid by a 15% if the recipient is the
company, which is a resident of the beneficial owner of the
Philippines registered with the Board of royalties
Investments and engaged in preferred
pioneer areas of investments under the
investment incentives laws of the
Philippines, to a resident of Korea, who
is the beneficial owner of the royalties
Kuwait KW 20% if the beneficial owner of the
royalties is a resident of the other
contracting state
Malaysia MY 15% if the recipient is the beneficial 25% in all other cases
owner of the royalties and where the
royalties are paid by a registered
enterprise as well as royalties for the
use of, or the right to use,
cinematograph films, or tapes for radio
or television broadcasting
Netherlands NL 10% if the recipient is the beneficial 15% in all other cases
owner of the royalties and where the
royalties are paid by an enterprise
registered, and engaged in preferred
areas of activities in that State
New Zealand NZ 15% if the recipient is the beneficial
owner of the royalties
Nigeria NG 20% if the recipient is the beneficial
owner of the royalties
Norway NO 25% when the royalties are taxable in 7.5% when the royalties are The lowest rate
the other Contracting State and for taxable in the other of the Philippine
amount paid for the use of, or the right Contracting State and paid for tax that may be
to use, motion picture films, films or the use of or the right to use imposed on
tapes for radio or television containers royalties of the
broadcasting same kind paid
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in similar
circumstances
to a resident of
a third State
Pakistan PK 15% where the royalties are paid by an 25% in all other cases
enterprise registered with, and
engaged in preferred areas of activities
in that Contracting State
Poland PL 15%
Qatar QA 15% if the beneficial owner of the
royalties is a resident of the other
contracting state
Romania RO 10% where the royalties are paid by an 15% in respect of 25% in all other
enterprise registered with the Board of cinematographic films and cases
Investments and engaged in preferred tapes for television of
pioneer areas of activities broadcasting
Russia RU 15%
Singapore SG 15% if the recipient is the beneficial 25% in all other cases
owner of the royalties and where the
royalties are paid by an enterprise
registered with the Philippine Board of
Investments and engaged in preferred
areas of activities and also royalties in
respect of cinematographic films or
tapes for television or broadcasting
Spain ES 10% if the recipient is the beneficial 15% in all other cases 20% if the
owner of the royalties and where the provided that the recipient is recipient is the
royalties are paid by an enterprise the beneficial owner of the beneficial owner
registered with the Philippine Board of royalties of the royalties
Investments and engaged in preferred and in respect
areas of activities of
cinematographi
c films or tapes
for television or
broadcasting
Sweden SE 15% if the beneficial owner of the
royalties is a resident of the other
Contracting State
Switzerland CH 15%
Thailand TH 15% if the recipient is the beneficial 25% in all other cases
owner of the royalties and if the provided that the recipient is
royalties are paid: the beneficial owner of the
royalties
(i) by an enterprise registered with the
Philippine Board of Investments
and engaged in preferred areas of
activities; or
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broadcasting process, or from the use of, or
the right to use, industrial,
commercial or scientific
equipment, or for information
concerning industrial,
commercial or scientific
experience
United Arab AE 10% if the beneficial owner of the
Emirates royalties is a resident of the other
Contracting State
United Kingdom GB 15% where the royalties are paid: 25% in all other cases
of Great Britain
and Northern (i) by an enterprise registered with the
Ireland Philippine Board of Investments
and engaged in preferred areas of
activity; or
Certificate of Residence
(for Tax Treaty Relief)
PART I
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Certificate of Residence
(for Tax Treaty Relief)
PART II
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Footnotes
1. 1.3 Connection between tax compliance and source withholding, Chapter IV,
United Nations Handbook on Selected Issues in Administration of Double Tax
Treaties for Developing Countries.
2. Ibid.
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3. OECD Commentary on Model Tax Convention on Income and Capital, par. 12.4
of Art. 10; par. 10.2 of Art. 11; and par. 4.3 of Art. 12.
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Endnotes
1 (Popup - Popup)
Annex A
2 (Popup - Popup)
1. 1.3 Connection between tax compliance and source withholding, Chapter IV,
United Nations Handbook on Selected Issues in Administration of Double Tax
Treaties for Developing Countries.
3 (Popup - Popup)
2. Ibid.
4 (Popup - Popup)
3. OECD Commentary on Model Tax Convention on Income and Capital, par. 12.4
of Art. 10; par. 10.2 of Art. 11; and par. 4.3 of Art. 12.
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