Aliens Employed by Regional or Area Headquarters in the Philippines Subject to Income Tax at Preferential Rate of 15% of Gross Income

June 10, 1981 BIR RULING NO. 093-81 22-c 000-00 093-81 Castillo, Laman, Tan and Pantaleon Salcedo Centre, 138 H.V. dela Costa St. Salcedo Village, Makati, Metro Manila Attention: Mr . Remie A . Noval Gentlemen : This refers to your letter dated May 5, 1981, requesting a ruling that the gross income received by Mr. Dirk Lushen, an alien executive of Reifenhauser KG in its Regional Office in the Philippines is subject to a final Philippine income tax at the rate of fifteen per centum (15%) of such gross income. It is represented that Reifenhauser KG is a multinational company organized and existing under the laws of West Germany duly registered with the Securities and Exchange Commission and authorized to establish a regional headquarter in the Philippines; that Mr. Dirk Lushen is one of its alien executive that will work exclusively for the Regional Office in the Philippines and will receive a salary of at least U.S. $12,000 per annum . cdtech In reply, please be informed that pursuant to Section 22(c) of the Tax Code, as amended, aliens employed by regional or area headquarters established in the Philippines by multinational corporations shall be subject to income tax at the rate of fifteen per centum (15%) of gross income. Moreover, the said tax shall be deducted and withheld at the source in the same manner and conditions as that provided under the Tax Code, as amended. (Sec. 4, P.D. No. 218.) Accordingly, Mr. Dirk Lushen, an alien executive of Reifenhauser KG in its Regional Office in the Philippines is subject to final income tax at the rate of fifteen per centum (15%) of gross income. Very truly yours, RUBEN B. ANCHETA Acting Commissioner