In March 2021, the Philippine Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order No. 014-21 (the Memorandum), which streamlines the procedures for non-resident corporations and other juridical entities (collectively “non-resident taxpayers”) to access Philippine tax treaty benefits.
Scope of Memorandum
The Memorandum covers Philippine-sourced income derived by non-resident taxpayers from the Philippines, which are entitled to relief from double taxation under a relevant tax treaty. In addition to streamlining the procedures in availing tax treaty benefits, the Memorandum:
- reformats the manner of confirming entitlement to tax treaty benefits;
- addresses pending applications for income earned in previous years; and
- prescribes penalties for the late filing of the relevant applications.
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