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changed by:
BRANCH PROFIT REMITTANCE TAX A. Assigned net Increase-
15% based on total profits Capital investment of addt'l
applied/earmarked for remittance without Accounsts the home investent of
any deduction for tax component office to the home office
BRANCH-Philippines; HEAD OFFICE-Abroad branch Decrease-
Final tax withheld at source by branch of withdrawal of
foreign corporation home office
Applicable for active income ONLY or B. net balance of
income from business related to trade or Accumulated unremitted,
business Profit/loss retained or
PASSIVE INCOME & GAINS--->EXCLUDED accumulated
Income must be derived from actual P/L of the
operation of the trade or business. branch since
Remittance of prior year is still taxable inception of
since NIRC used the term “any profit operation
remitted”
DIFFERENTIATION ON FOREIGN PROFIT
SCOPE OF BRANCH PROFIT REMITTANCE TAX REMITTANCE
ALL RFC, including ROHQs of multinational Remitting entity to its
TAX RATE
companies, EFCDU or OBU of foreign banks head office
and international carriers except Branch of RFC 15% branch
PEZA-registered entities. remittance
Subsidiary of a foreign
30% FT, 15% if the tax
INDIRECT REMITTANCE corporation through
sparring rule applies
increase of home office’s capital or dividend declaration
investment Branch of domestic
Not subject to tax
1. Remittance of resident affiliate/Phil ROHQ corporation
of the home office