Salary and Allowances Received by an Australian citizen, as Resident Manager of the Qantas Empire Airways, Ltd.

July 13, 1959 BIR RULING NO. 324-59 The Treasurer Warner, Barnes & Co., Ltd. P. O. Box 294, Manila S i r : In reply to your letter dated July 10, 1959, wherein you requested this Office to confirm your stand to the effect that Mr. Athol Bulmer, an Australian citizen, is subject to Philippine income tax on the salary and allowances he received for services rendered here as resident manager of the Qantas Empire Airways, Ltd., during the period from December 9, 1958 to March 19, 1959, please be informed as follows: During the period when Mr. Bulmer was temporarily serving as resident manager of the said airline in Manila, he was, for purposes of the income tax law, considered a non-resident alien engaged in business or having an office in this country. Non-resident aliens engaged in business or having an office in this country are subject to income tax on their net income received from all sources within the Philippines. (Section 22(a), Tax Code). Compensation for services performed here is income from sources within the Philippines. (Sec. 37(a)(3), Tax Code). As the salary and allowances in question, were received by Mr. Bulmer for services performed by him in the Philippines, this office believes that said salary and allowances are subject to Philippine income tax, Mr. Bulmer is, however, entitled to the deductions allowed under section 30 of the Tax Code. cd Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue