Authorizing the Use of BIR Form No. 1928 — Application for Relief from Double Taxation (Gains from Sale or Transfer of Shares of Stock in Philippine Corporation) for Processing of Tax Treaty Relief Applications Involving Gains from Sale or Transfer of Shares of Stocks in a Philippine Corporation Including Gains from Sale or Transfer of Unit of Participation in a Philippine Partnership

November 4, 2002 REVENUE MEMORANDUM ORDER NO. 30-02 SUBJECT : Authorizing the Use of BIR Form No. 1928 Application for Relief from Double Taxation (Gains from Sale or Transfer of Shares of Stock in Philippine Corporation) for Processing of Tax Treaty Relief Applications Involving Gains from Sale or Transfer of Shares of Stocks in a Philippine Corporation Including Gains from Sale or Transfer of Unit of Participation in a Philippine Partnership TO : All Internal Revenue Officers and Others Concerned I. OBJECTIVE This Order is issued to authorize the use of BIR Form No. 1928 Application for Relief From Double Taxation (Gains from Sale or Transfer of Shares of Stock in Philippine Corporation) and the corresponding Certification detailing the relief granted as well as the tax consequences of transactions involving gains from sale or transfer of shares or stocks in a Philippine corporation including sale or transfer of unit of participation in a Philippine partnership. II. COVERAGE This Order covers exclusively applications for tax treaty relief on income derived or to be derived by the taxpayer under existing tax treaties particularly on gains from sale or transfer of shares of stock in Philippine corporation including sale or transfer of unit of participation in a Philippine partnership. III. PAYMENT OF FEES Pursuant to Executive Order No. 159, " Directing All Departments, Bureaus, Offices, Units And Agencies Of The National Government, Including Government-Owned Or Controlled Corporations, To Revise Their Fees And Charges At Just And Reasonable Rates Sufficient To Recover At Least The Full Cost Of Services Rendered " as amended by Executive Order No. 197, " Directing All Departments, Bureaus, Commissions, Agencies, Offices And Instrumentalities Of The National Government, Including Government-Owned Or Controlled Corporations, To Increase Their Rates of Fees And Charges By Not Less Than 20 Percent ," the taxpayer shall pay the applicable processing and certification fee in the amount of P5,000.00 in the district having jurisdiction over the place of business of the Philippine corporation using BR Form No. 0605, before filing the application for tax treaty relief with the International Tax Affairs Division. Proof of payment of the processing and certification fee must be submitted upon filing of application for tax treaty relief. IV AUTHORIZED SIGNATORY The Certification shall state the relief granted as well as the tax consequences, if any, involving gains from sale or transfer of the shares of stock in a Philippine corporation, including gains from sale or transfer of unit of participation in a Philippine partnership, and shall be signed by the Assistant Commissioner for Legal Service or whoever shall hereafter be delegated to sign it. V. REPEALING CLAUSE This Order modifies RMO No. 1-2000 dated November 25, 1999 and amends all other issuances and portions thereof inconsistent herewith. VI. EFFECTIVITY This Order takes effect immediately. IScaAE (SGD.) GUILLERMO L. PARAYNO, JR. Commissioner of Internal Revenue ATTACHMENT Certification BIR FORM NO. 1928 APPLICATION FOR RELIEF FROM DOUBLE TAXATION