Double Taxation pep Agreements oy ' Discussion outline age? Tex uscaterDiscussion outline Double Taxation Agreements Pago 2 Background Permanent Establishment Business Profits Royalties Dividends Interest Capital Gains Dependent Personal Services "ee Updt “Double Taxation Agreements Philippine Tax Rules 1997 ‘Philippine Tax Code Grants taxiexemptions through treaties entered into by : the Philippine government and other sovereign states Exclusion from gross income: “Income of any kind, to:theextent required by any treaty obligation binding upon the.Philippines [Sec. 32(B)(5), Tax Code]Double Taxation Agreements Philippine Tax Rules ‘Taxpayer Situs of Taxation Resident citizen Within and without Non-resident citizen Within Citizen working and deriving income it abroad as OFW iin Alien individual (resident or non-resident) Within Domestic corporation Within and without Foreign corporation (resident or non- te resident) os Pages 8 Double Taxation Agreements Tax Treaty Definition An mternational'agreement by which states reciprocally agree to limit or modify the application of their domestic law to avoid international double taxation in situations falling within the scope of the agreement. 18 Aupsst 2017