KINDS OF TAXPAYERS AND SITUS OF
Aliens – An alien is a foreign-born
INCOME
Classification of Taxpayers / Income Earners
A. Individuals
a. Citizens – (1)Those who are citizens of
the Philippines at the time of adoption
of the 1987 Constitution; (2)Those
whose parents are citizens of the
Philippines; (3) Those born before
January 17, 1973 of Filipino Mothers,
who elect Philippine Citizenship upon
reaching the age of maturity; (4) Those
who are naturalized in accordance with
the law.
i. Resident Citizen – resides or
stays in the Philippines
permanently or stays outside
the Philippines for less than 183
days during a particular taxable
year.
ii. Non-resident Citizen – (1)
establishes the fact of his
physical presence abroad with a
definite intention to reside
therein; (2) leaves the
Philippines during the taxable
year to reside abroad as an
immigrant or for employment
on a permanent basis or for
work and derives income from
abroad and whose employment
thereat requires him to be
physically present abroad most
of the time during tha taxable
year; (3) a citizen of the
Philippines who shall have
stayed outside the Philippines
for 183 days or more by the end
of the year.
b.
person who is not qualified to acquire
Philippine Citizenship by birth or after
birth.
i. Resident Alien – those who
resides in the Philippines, but is
not a citizen thereof. This
includes foreign individuals
whose stay in the Philippines
has exceeded one year from the
date of their arrival.
ii. Non-resident Alien
1. Engaged in Trade or
Business w/in the
Philippines – an alien who is
not a citizen and who is not
a resident of the Philippines,
but has a business,
particularly a sole
proprietorship, established
and operating in the
Philippines, or a non-
resident alien who comes to
the Philippines and stays for
an aggregate period of more
than 180 days during the
taxable year.
2. Not Engaged in Trade or
Business w/in the
Philippines – if an alien
stays in the Philippines for
only 180 days or less, or he
is not deriving business
income in the Philippines.
TAXABILITY OF INDIVIDUAL TAXPAYERS

Classification Income Income

W/in W/out
Resident Citizen  
Non-resident 
Citizen
Resident Alien 
Non-RAETB 
Non-RANETB 

SITUS OF INCOME:

TYPES OF INCOME PLACE of TAXATION

Interest Income Debtor’s Residence
Royalties Where intangible is
employed
Rent Income Location of property
Service Income Place where service is
rendered
Gain on Sale of Property:
Personal Property
1. Domestic Presumed Within
Securities
2. Other Personal Place where property is
Properties. sold

Real Properties Location of the Property

Dividends From:
a. Domestic Co. Presumed Within
b. Foreign Co. Depends on the pre-
dominance test
Merchandising Income Where the property is
sold
Manufacturing Income Where the goods are
manufactured and sold.