Entry into Force and Applicability on Income of the Convention between the Rep. of the Phils. and the Swiss Confederation

June 10, 2002 REVENUE MEMORANDUM CIRCULAR NO. 19-02 SUBJECT : Entry into Force and Applicability on Income of the Convention between the Republic of the Philippines and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income and Agreement between the Government of the Republic of the Philippines and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income TO : All Internal Revenue Officers, Employees and Others Concerned For the information and guidance of all internal revenue officers, employees and others concerned: a) The Convention between the Republic of the Philippines and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income which was signed in Manila on June 24, 1998 entered into force on April 30, 2001 upon the exchange of Instruments of Ratification in Berne, Switzerland. Its provisions on taxes apply on income derived or which accrued beginning January 1, 2002. b) The Agreement between the Government of the Republic of the Philippines and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income which was signed in Beijing, China on November 18, 1999 entered into force on March 23, 2001 when the Philippines notified China of the completion of the constitutional requirements to bring the Agreement into force. Its provisions on taxes apply on income derived or which accrued beginning January 1, 2002. Any person/enterprise who is entitled to the benefits provided by these treaties may file BIR Form No. 0901 (Application for Relief from Double Taxation) with the International Tax Affairs Division, Bureau of Internal Revenue, National Office Bldg., Diliman, Quezon City. In case the applicant resides outside Metro Manila, he may file the appropriate BIR Form with the Regional Office nearest his residence, which shall forward the same to the International Tax Affairs Division for proper action. It is desired that this Circular be given the widest publicity possible. (SGD.) REN G. BAEZ Commissioner of Internal Revenue