BIR Ruling No. 061-83

April 14, 1983 BIR RULING NO. 061-83 S i r : This refers to your letter dated January 14, 1983 requesting for a refund of Philippine income taxes you paid as a Filipino permanent resident of the United Kingdom. In reply, please be informed that under the Convention between the Government of the Republic of the Philippines and the Government of the United Kingdom of Great Britain and Northern Ireland, it provides in Article 1, paragraph 2 that the Philippines retains its right to tax its own citizens who are residents of the United Kingdom. Section 21 of the Philippine National Internal Revenue Code provides that non-resident citizens are subject to income tax upon the adjusted gross income derived by them from all sources without the Philippines. By virtue of your physical presence in the United Kingdom with definite intention to reside therein you are considered a non-resident citizen. [Sec. 20 (e)(i), Tax Code]. Accordingly, you are subject to Philippine income tax on income derived by you in the United Kingdom. Such being the case, you are not entitled to the refund of said taxes. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue