4B Special RFC

TAX ON SPECIAL RESIDENT FOREIGN CORPORATIONS

Optional Standard Inter-Corporate
Income Taxpayer Tax Rates Exemptions Itemized Deductions MCIT IAET BPRT
Deductions Dividend
Personal 50K Additional 25K
MAINTAINS FLIGHTS to & from Philippines = 2.5% on GROSS PHILIPPINE BILLINGS p100 Ingles N/A N/A N/A N/A YES
NO FLIGHTS to & from Philippines = EXEMPT from GPB N/A N/A N/A N/A N/A
NO FLIGHTS to & from Philippines but nonetheless earn income from other activities in the country = 30% NCIT for other
International Carriers activities but EXEMPT from GPB YES if taxed under
YES if taxed under NCIT. YES if taxed under NCIT.
NCIT. Otherwise,
Otherwise, NO Otherwise, NO
NOTE: if they maintain a general sales agent in the Philippines that sells airline tickets they shall be taxed for the sale of such NO
(NCIT) - CIR vs BOAC EXEMPT N/A
GEN RULE: EXEMPT
( Income of NON-RESIDENTS (NRC, NRAETB, NRANETB, NRFC) from transactions with depositary banks under the expanded
FCDS are EXEMPT from Income Tax)
Offshore Banking Units
Exp: 10% FWT on interest income derived from foreign currency loans granted to residents other than offshore banking units NOT APPLICABLE TO CORPORATE
EXEMPT (RR 9-1998)
or local commercial banks including local, branches of foreign banks that may be authorized by the BSP to transact business TAXPAYERS
with offshore banking units N/A N/A N/A N/A N/A

Resident Depositary Bank (FCDU) GEN RULE: EXEMPT from all taxes except net income from such transactions as may be specified by the Secretary of Finance,
upon recommendation of the Monetary Board which shall be subject to the regular income tax payable by banks
N/A N/A N/A N/A N/A
Regional or Area Headquarters
(RAHQ) and Regional Operating RAHQ = EXEMPT N/A N/A N/A N/A N/A
Headquarters (ROHQ) of
Multinational Companies p 104
ROHQ: 10% of Taxable Income (NIT) from sources within the Philippines N/A N/A N/A N/A YES

4C Special NRFC

TAX ON SPECIAL NON-RESIDENT CORPORATIONS

Itemized Inter-Corporate
Income Taxpayer Tax Rates Exemptions OSD MCIT IAET BPRT
Deductions Dividend
Personal Additional
50K 25K
Nonresident Cinematographic Film Owner, 25% of its Gross Income from all sources within the Philippines.
Lessor or Distributor
NOT APPLICABLE 15% - With Tax
NOT APPLICABLE
Nonresident Owner or Lessor of Vessels 4.5% of Gross Rentals, lease or charter fees from leases or charters to Filipino citizens or NOT APPLICABLE TO TO NRFC - THEY Sparing; 30% - NOT APPLICABLE
TO NRFC - THEY PAY N/A N/A
Chartered by Philippine Nationals corporations, as approved by the Maritime Industry Authority. CORPORATE TAXPAYERS PAY BY WAY OF Without Tax Sparing TO NRFC
BY WAY OF GIT
GIT (Spare)
Nonresident Owner or Lessor of Aircraft, 7.5% of of Gross Rentals or Fees
Machineries and Other Equipment.
 TAX ON SPECIAL NON-RESIDENT CORPORATIONS
Itemized Inter-Corporate
Income Taxpayer Tax Rates Exemptions OSD MCIT IAET BPRT
Deductions Dividend
Personal Additional
50K 25K
Nonresident Cinematographic Film Owner, 25% of its Gross Income from all sources within the Philippines.
Lessor or Distributor
NOT APPLICABLE 15% - With Tax
NOT APPLICABLE
Nonresident Owner or Lessor of Vessels 4.5% of Gross Rentals, lease or charter fees from leases or charters to Filipino citizens or NOT APPLICABLE TO TO NRFC - THEY Sparing; 30% - NOT APPLICABLE
TO NRFC - THEY PAY N/A N/A
Chartered by Philippine Nationals corporations, as approved by the Maritime Industry Authority. CORPORATE TAXPAYERS PAY BY WAY OF Without Tax Sparing TO NRFC
BY WAY OF GIT
GIT (Spare)
Nonresident Owner or Lessor of Aircraft, 7.5% of of Gross Rentals or Fees
Machineries and Other Equipment.