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Non-Resident Alien Engaged in Trade or Business in the Philippines Subject to Income Tax

BIR Ruling No. 080-84 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Apr 26, 1984

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April 26, 1984 BIR RULING NO. 080-84 22-a-51-81-080-84 Gentlemen : In reply to your letter dated November 16, 1982, please be informed that Mr. Mandor Fastad, a Norwegian assigned in the Philippines for approximately one year as Marketing Specialist on the Northern Palawan Fisheries Development Project assigned to Norconsult A.S. by the Philippine Fish Marketing Authority is considered a non-resident alien engaged in trade or business in this country. Hence, he is subject to income tax imposed by Section 21 of the Tax Code based on his entire net income received from all sources in the Philippines. (Sec. 22(a), Tax Code) Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner

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