Filing of Income Tax Returns by Nonresident Alien Individuals and Corporations

March 14, 1966 BIR RULING NO. 011-66 Messrs. Ozaeta, Gibbs & Ozaeta Attorneys-at-Law P. O. Box 758 M a n i l a Gentlemen : This refers to your letter dated January 17, 1966 requesting a ruling on the following query: cdi "A nonresident alien individual or corporation with no trade or business in the Philippines receives dividends and interest from Philippine sources from which corresponding withholding tax was withheld by the withholding agent. The latter in due time files a withholding return and pays the corresponding withholding tax to the Government. If no other income from Philippine sources was received, does the nonresident alien individual or corporation have to file an income tax return?" In reply, I have the honor to inform you that, under the provisions of Sections 22(b) and 24(b) of the Tax Code, both as amended by Republic Act No. 2343, non-resident alien individuals and foreign corporations not engaged in trade or business in the Philippines are now subject to tax in their entire income from sources within the Philippines which tax is subject to withholding pursuant to Sections 53 and 54 of the Tax Code. Such being the case, it may no longer be necessary for non-resident alien individuals and foreign corporations not engaged in trade or business in the Philippines to file an income tax return. The provisions of Sections 45 and 46 of the Tax Code referring to filing of returns by non-resident alien individuals and foreign corporations should now be understood as referring to those engaged in trade or business in the Philippines. cdtech Very truly yours, (SGD.) MISAEL P. VERA Commissioner of Internal Revenue