29 August 2016 Philippines releases draft automatic treaty rates application procedures for dividend, interest and royalty payments to nonresidents Following the suspension of the automatic treaty rate applications to dividend, interest and royalty payments to nonresidents, on August 22, the Philippines Bureau of Internal Revenue (BIR) released a draft memorandum order (the Draft Order) for public comments on the new procedures. The Draft Order in essence replaces the mandatory Tax Treaty Relief Application (TTRA) Form and requires the nonresident to submit to its withholding agent a Certificate of Residence for Tax Treaty Relief Form (COR Form) to be filed with the BIR International Tax Affairs Division (ITAD). The COR Form should be certified and sealed by the competent authority or authorized tax office of the treaty partner country where the nonresident resides. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1464 |