Non-taxability of Phelps Dodge Copper Products International Corporation

September 8, 1959 BIR RULING NO. 432-59 Phelps Dodge Copper Products Corporation of the Philippines Soriano Building, Manila Gentlemen : With reference to your letter dated March 31, 1959, requesting a ruling whether or not the Phelps Dodge Copper Products International Corporation, a non-resident foreign corporation, is subject to income tax on fees received in 1958 for services it rendered to you outside the Philippines, I have the honor to inform you that, it appearing upon investigation that the services consisted of the training of your personnel and the procurement of plant equipment and raw materials in the United States, said fees are not subject to income tax in this jurisdiction. prcd Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue