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| Permanent
establishment (PE) |
Period test for
PE: 6 months for a building site, construction,
installation or assembly project; or supervisory
activities in connection with the above. |
| Air transport
and shipping |
Exempt |
| Dividends |
15% |
| Interest |
10% |
| Royalties |
10% |
| Treatment
of Capital Gains |
Domestic law
applies. |
| Personal services |
Remuneration
derived by an individual who is a resident of a
Contracting State from personal services performed
in the other Contracting State is exempt from tax
in the latter if
a) he is present in the other Contracting for less
than 183 days;
b) services are performed on behalf of a person
who is a resident of the first- mentioned Contracting
State and
c) remuneration is not deductible for tax purposes
in the other Contracting State of a PE in that other
Contracting State of that person. |
| Independent
personal services |
Remuneration
derived by an individual who is a resident of a
Contracting State from personal services shall be
taxable only in that Contracting State unless the
services are performed in the other Contracting
State. |
| Permanent
establishment (PE) |
Period test
for PE:
-183 days for a building site, construction, installation
or assembly project; or supervisory activities in
connection with the above;
-183 days for furnishing of services or facilities
in connection with exploration, exploitation or
extraction of mineral oils;
-For furnishing of services (other than the above
services and technical services as defined in Article
12), these period test apply: 30 days for activities
performed for a related enterprise (within meaning
of Article 9) and 90 days for others. |
| Air transport
and shipping |
Exempt |
| Dividends |
10% (at least
25% shareholding) and 15% for others |
| Interest |
10% (loan granted
by a bank or by a similar financial institution
including an insurance company) and 15% for others |
| Royalties |
10% (for any
industrial, commercial or scientific equipment)
and 15% for others |
| Treatment
of Capital Gains |
Gains from sale
of shares in a company resident in a Contracting
State may be taxed in that Contracting State. Otherwise,
gains taxable only in the Contracting State where
the seller is a resident. |
| Personal services |
Remuneration
derived by a resident of a Contracting State in
respect of employment exercised in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting for less
than 183 days;
b) remuneration is paid by, or on behalf of, an
employer who is not a resident of the other Contracting
State;
c) remuneration is not borne by a PE or a fixed
base which the employer has in the other Contracting
State.
If the remuneration is deductible against technical
fees derived by employer who has no PE in the other
Contracting State, tax chargeable at 15% of gross
remuneration in the other Contracting State. |
| Independent
personal services |
Income derived
by an individual who is a resident of a Contracting
State from professional services or other activities
of an independent character performed in the other
Contracting State is taxable in the latter if:
a) a fixed base is present;
b) he is present in the other Contracting for more
than 183 days. |
| Permanent
establishment (PE) |
Period test
for PE:
-183 days for a building site, construction, installation
or assembly project;
-90 days for furnishing of services, including consultancy
services, by an enterprise through an employee or
other person. |
| Air transport
and shipping |
Air transport:
Exempt
Shipping: 50% of normal rate |
| Dividends |
10% (at least
25% shareholding) and 15% for others |
| Interest |
10% |
| Royalties |
15% |
| Treatment
of Capital Gains |
No Capital Gains
article |
| Personal services
|
Remuneration
derived by a resident of a Contracting State in
respect of employment exercised in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting State
for less than 183 days;
b) remuneration is paid by, or on behalf of, an
employer who is a resident of the first-mentioned
State;
c) remuneration is not borne by a PE which the employer
has in the other Contracting State. |
| Independent
personal services |
Income derived
by a resident of a Contracting State from professional
services or other activities of an independent character
performed in the other Contracting State is taxable
in the latter if he is present in the other Contracting
for more than 90 days. |
| Permanent
establishment (PE) |
Period test
for PE: 6 months for a building site, construction,
or installation project or supervisory activities
in connection with the above. |
| Air transport
and shipping |
Exempt |
| Dividends |
5% (at least
25% shareholding) and 15% for others |
| Interest |
Exempt (Government
approved undertaking) and 10% for others |
| Royalties |
10% |
| Treatment
of Capital Gains |
Generally, taxable
only in the Contracting State where the seller is
a resident but gains from sale of shares in a company
resident in a Contracting State may be taxed in
that Contracting State if:
a) seller with related persons holds at least 25%
of the entire share capital; and
b) seller and related persons sold at least 5% of
the entire share capital. |
| Personal services |
Remuneration
derived by resident of a Contracting State in respect
of employment exercised in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting State
for less than 183 days;
b) remuneration is paid by, or on behalf of, an
employer who is a resident of the first-mentioned
State;
c) the remuneration is not borne by a PE which the
employer has in the other Contracting State. |
| Independent
personal services |
Income derived
by a resident of a Contracting State in respect
of professional services or other activities of
an independent character performed in the other
Contracting State shall be taxable only in the latter
if:
a) a fixed base is present;
b) he is present in the other Contracting for more
than 183 days in any consecutive 12-month period. |
| Permanent
establishment (PE) |
Building site,
construction, installation or assembly project or
supervisory activities connected with such site
or project is a PE without any period test. |
| Air transport
and shipping |
50% of normal
rate |
| Dividends |
50% of normal
rate |
| Interest |
Normal rate |
| Royalties |
Normal rate |
| Treatment
of Capital Gains |
No Capital Gains
article |
| Personal services
|
Income derived
by an individual who is a resident of a Contracting
State in respect of employment exercised in the
other Contracting State shall be taxable only in
the first-mentioned State if:
a) he is present in the other Contracting State
for less than 120 days;
b) the services are performed for, or on behalf
of, a resident of the first-mentioned State;
c) income is subject to tax in the first-mentioned
State;
d) income is not deductible for tax purposes in
the other Contracting State from the income of a
PE of that person in the other Contracting State. |
| Independent
personal services |
No provision |
| Permanent
establishment (PE) |
Period test
for PE:
-183 days for a building site, construction, installation
or assembly project;
-183 days for furnishing of services, including
consultancy services, by an enterprise through an
employee or other person. |
| Air transport
and shipping |
Lower of 1.5%
of gross revenue or lowest rate of Philippines tax
on similar profits of residents of a third state. |
| Dividends |
15% (at least
15% shareholding) and 25% for others |
| Interest |
Exempt (loan
guaranteed/insured by approved institutions)10%
(public bond issued by Philippines resident co.)
and 15% for others |
| Royalties |
Exempt (Singapore
approved EEIA royalties), 15% (Philippines approved
royalties) and 25% for others. |
| Treatment
of Capital Gains |
Taxable only
in the Contracting State where the seller is a resident. |
| Personal services |
Remuneration
derived by a resident of a Contracting State for
personal services performed in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting State
for less than 183 days;
b) remuneration is paid by, or on behalf of, a person
who is a resident of the first-mentioned State;
c) remuneration is not borne directly by a PE in
the other Contracting State. |
| Independent
personal services |
Income derived
by a resident of a Contracting State from personal
services shall be taxable only in that Contracting
State, unless the resident is present for more than
90 days in the other Contracting State. |
| Permanent
establishment (PE) |
Period test for
PE: 6 months for a building site, construction,
installation or assembly project |
| Air transport
and shipping |
Exempt |
| Dividends |
10% (at least
25% shareholding) and 15% for others |
| Interest |
10% |
| Royalties |
15% |
| Treatment
of Capital Gains |
Taxable in the
Contracting State where gains arise and also taxable
in the Contracting State where the seller is a resident. |
| Personal services |
Income derived
by a resident of a Contracting State from personal
services performed in the other Contracting State
is exempt from tax in the latter if
a) he is present in the other Contracting for less
than 183 days;
b) remuneration is paid by, or on behalf of, a person
who is a resident of the first-mentioned State;
c) remuneration is not borne by a PE which that
person has in the other Contracting State. |
| Independent
personal services |
Income derived
by a resident of a Contracting State from personal
services shall be taxable only in that Contracting
State, unless the services are performed in the
other Contracting State. |
| Permanent
establishment (PE) |
Period test for
PE: 6 months for a building site, construction,
installation or assembly project |
| Air transport
and shipping |
Air transport:
Exempt
Shipping: Maximum 2% of gross revenue |
| Dividends |
Dividend and
corporate tax rate together constitute maximum 40%
of income |
| Interest |
Not covered by
agreement |
| Royalties |
15% |
| Treatment
of Capital Gains |
No Capital gains
article |
| Personal services
|
Income derived
by a resident of a territory from personal services
performed in the other territory is exempt from
tax in the latter if
a) he is present in the other Contracting for less
than 183 days;
b) remuneration is paid by, or on behalf of, a person
who is a resident of the first-mentioned territory;
c) remuneration is not borne by a PE which that
person has in the other territory. |
| Independent
personal services |
Income derived
by a resident of a territory from personal services
shall be taxable only in that territory, unless
the services are performed in the other territory. |
| Permanent
establishment (PE) |
Period test
for PE: 6 months for a building site, construction,
or assembly project; or supervisory activities in
connection with the above. |
| Air transport
and shipping |
Exempt |
| Dividends |
15% |
| Interest |
15% |
| Royalties |
15% |
| Treatment
of Capital Gains |
Taxable only
in the Contracting State where the seller is a resident
but the other Contracting State may tax if the seller
was previously a resident of the other Contracting
State at any time during the 6 years immediately
before sale. |
| Personal services |
Remuneration
derived by a resident of a Contracting State in
for personal services performed in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting for less
than 183 days;
b) remuneration is paid by, or on behalf of, a person
who is a resident of the first-mentioned Contracting
State;
c) remuneration is not borne by a PE which the person
has in the other Contracting State. |
| Independent
personal services |
Remuneration
derived by a resident of a Contracting State from
personal services shall be taxable only in that
Contracting State, unless the services are performed
in the other Contracting State. |
| Permanent
establishment (PE) |
Period test
for PE:
-6 months for a building site, construction, installation
or assembly project; or supervisory activities in
connection with the above;
-6 months for furnishing of services (including
consultancy services) by an enterprise of a Contracting
State through employees or other personnel in the
other Contracting State. |
| Air transport
and shipping |
Exempt |
| Dividends |
7% (at least
25% shareholding) and 12% for others |
| Interest |
7% (for financial
institutions) and 10% for others |
| Royalties |
10% |
| Treatment
of Capital Gains |
May be taxed
in the Contracting State where the gains arise. |
| Personal services |
Remuneration
derived by resident of a Contracting State in respect
of employment exercised in the other Contracting
State shall be taxable only in the first-mentioned
State if:
a) he is present in the other Contracting for less
than 183 days;
b) remuneration is paid by, or on behalf of, an
employer who is not a resident of the other Contracting
State;
c) remuneration is not borne by a PE or a fixed
base which the employer has in the other Contracting
State. |
| Independent
personal services |
Income derived
by an individual who is a resident of a Contracting
State from professional services or other activities
of an independent character performed in the other
Contracting State is taxable in the latter if:
a) a fixed base is present;
b) he is present in the other Contracting for more
than 183 days. |
| Permanent
establishment (PE) |
Period test for
PE: 6 months for a building site, construction,
installation or assembly project. |
| Air transport
and shipping |
Air transport:
Exempt
Shipping: 50% of normal rate |
| Dividends |
20% (at least
25% shareholding); and normal rate for others |
| Interest |
10% (received
by financial institutions) and 25% for others |
| Royalties |
15% |
| Treatment
of Capital Gains |
Taxable only
in the Contracting State where the seller is a resident
except for gains from the sale of intellectual property
which will be taxed at 15% in the Contracting State
where the gains arise. |
| Personal services |
Income derived
by a resident of a Contracting State from personal
services performed in the other Contracting State
shall be taxable only in the first-mentioned State
if
a) he is present in the other Contracting for less
than 183 days;
b) services are rendered for or on behalf of a person
who is a resident of the first-mentioned State;
c) the remuneration is not borne by a PE which the
person has in the other Contracting State. |
| Independent
personal services |
Income derived
by a resident of a Contracting State from personal
services shall be taxable only in that Contracting
State, unless the services are performed in the
other Contracting State. |
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