New Zealand - Philippines Tax Treaty

Reprint as at 22 July 2004 Double Taxation Relief (Republic of the Philippines) Order 1980 (SR 1980/215) Keith Holyoake, Governor-General Order in Council

At the Government House at Wellington this 20th day of October 1980 Present:

His Excellency the Governor-General in Council Pursuant to section 294 of the Income Tax Act 1976, His Excellency the Governor-General, acting by and with the advice and consent of the Executive Council, hereby makes the following order. Contents

Page 1 Title and commencement 2 2 Giving effect to Convention 2

Note Changes authorised by section 17C of the Acts and Regulations Publication Act 1989 have been made in this reprint.

A general outline of these changes is set out in the notes at the end of this reprint, together with other explanatory material about this reprint.

This order is administered by the Inland Revenue Department. 1 cl 1 Double Taxation Relief (Republic of the Philippines) Order 1980 Reprinted as at 22 July 2004

Schedule 1 Convention between the Government of New Zealand and the Government of the Republic of the Philippines for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 3 1 (1) (2) 2 Schedule 2 32 Protocol amending the Convention between the Government of New Zealand and the Government of the Republic of the Philippines for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income

Order Title and commencement This order may be cited as the Double Taxation Relief (Repub- lic of the Philippines) Order 1980. This order shall be deemed to have come into force on 1 April 1980.

Giving effect to Convention It is hereby declared that the arrangements specified in the Convention set out in Schedules 1 and 2, being arrangements that have been made with the Government of the Republic of the Philippines with a view to affording relief from dou- ble taxation in relation to income tax and excess retention tax imposed under the Income Tax Act 1976 and income taxes im- posed under Title II of the National Internal Revenue Code of the Philippines as amended from time to time shall, in relation to income tax and excess retention tax imposed under that Act, and notwithstanding anything in that Act or any other enact- ment, have effect according to the tenor of the Convention.

Clause 2: amended, on 22 July 2004, by clause 3 of the Double Taxation Relief (Republic of the Philippines) Amendment Order 2004 (SR 2004/180). 2

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1

Schedule 1 Convention between the Government of New Zealand and the Government of the Republic of the Philippines for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Schedule heading: substituted, on 22 July 2004, by clause 4 of the Dou- ble Taxation Relief (Republic of the Philippines) Amendment Order 2004 (SR 2004/180). The Government of New Zealand and the Government of the Repub- lic of the Philippines, Desiring to conclude a Convention for the avoidance of double tax- ation and the prevention of fiscal evasion with respect to taxes on income, Have agreed as follows:

Article 1 Personal scope

This Convention shall apply to persons who are residents of one or both of the Contracting States.
Nothing in this Convention shall be construed as preventing the Philippines from taxing, in accordance with its domes- tic legislation, Filipino citizens who may be residents of New Zealand. New Zealand, however, is not obliged to give credit for the Philippine tax imposed by virtue of this reservation.

Article 2 Taxes covered

This Convention shall apply to taxes on income imposed by a Contracting State, irrespective of the manner in which they are levied.
All taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, shall be regarded as taxes on income.
The existing taxes to which the Convention shall apply are in particular: 3

Schedule 1 (a) (b) Double Taxation Relief (Republic of the Reprinted as at Philippines) Order 1980 22 July 2004 Article 2—continued in New Zealand:

the income tax and the excess retention tax (hereinafter referred to as “New Zealand tax”);

in the Philippines:

the income taxes imposed under Title II of the National Internal Revenue Code of the Philippines as amended from time to time (hereinafter referred to as “Philippine tax”).

The Convention shall apply also to any identical or substan- tially similar taxes on income which are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contract- ing States shall notify each other of any significant changes which have been made to their respective taxation laws relat- ing to the taxes to which this Convention applies.

Article 3 General definitions

For the purpose of this Convention, unless the context other- 4 wise requires:

(a)(i) the term “New Zealand”, when used in a geographical sense, means the metropolitan territory of New Zealand (including the outlying islands) but does not include the Cook Islands, Niue or Tokelau; it also includes areas adjacent to the territorial sea of the metropolitan territory of New Zealand (including the outlying islands) which by New Zealand legislation and in accordance with international law have been, or may hereafter be, designated as areas over which New Zealand has sovereign rights for the purposes of exploring them or of exploring, exploiting, conserving and managing the natural resources of the sea, or of the sea-bed and sub-soil;

(a)(ii) the term “Philippines” means the Republic of the Philippines and when used in a geographical sense

Reprinted as at 22 July 2004 (b) (c) (d) (e) (f) (g) (h) Double Taxation Relief (Republic of the Philippines) Order 1980 Schedule 1 Article 3—continued

means the national territory comprising the Republic of the Philippines;

the terms “a Contracting State” and “the other Contract- ing State” mean, as the context requires, New Zealand or the Philippines;

the term “person” includes an individual, an estate, a trust, a company, and any other body of persons; the term “company” means any body corporate or any entity which is treated as a body corporate for tax pur- poses; the terms “enterprise of a Contracting State” and “enter- prise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;

the term “international traffic” means any transport by a ship or aircraft operated by an enterprise of one of the Contracting States, except when the ship or aircraft is operated solely between places in the other Contracting State;

the term “national” means: (i) any individual possessing the citizenship of a Contracting State;

(ii) any legal person, partnership or association cre- ated, organised or incorporated under the laws of a Contracting State;

the term “competent authority” means:

(i) in the case of New Zealand, the Commissioner of Inland Revenue or his authorised representative;

(ii) in the case of the Philippines, the Minister of Finance or his authorised representative.

regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention

As applies. 5

Double Taxation Relief (Republic of the Reprinted as at Schedule 1 Philippines) Order 1980 22 July 2004

Article 4 Resident

For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.
Where, by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determined as follows:

(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both Contract- ing States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);

(b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode;

(c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national;

(d) if he is a national of both States or of neither of them, the competent authorities of the Contracting State shall settle the question by mutual agreement.

Where, by reason of paragraph 1, a person other than an indi- vidual is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question having regard to its day to day management, the place where it is incorporated or otherwise constituted and any other relevant factors. 6

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1 Article 5 Permanent establishment

For the purposes of this Convention, the term “permanent es- tablishment” means a fixed place of business through which the business of the enterprise is wholly or partly carried on.
The term “permanent establishment” includes especially:

(a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources;

(g) a place of exploration of natural resources;

(h) a building site or construction, installation or assembly project, or supervisory activities in connection there- with where such site, project or activity continues for more than six months;

(i) premises used as a sales outlet;

(j) a warehouse, in relation to a person providing storage mainly for some other person or persons;

(k) a place for the furnishing of services, including con- sultancy services by an enterprise through employees or other personnel where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than 183 days within any twelve month period.

Notwithstanding the preceding provisions of this Article, the term “permanent establishment” shall be deemed not to in- clude:

(a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;

(b) the maintenance of a stock of goods or merchandise be- longing to the enterprise solely for the purpose of stor- age, display or delivery;

(c) the maintenance of a stock of goods or merchandise be- longing to the enterprise solely for the purpose of pro- cessing by another enterprise; 7

Schedule 1 (d) (e) Double Taxation Relief (Republic of the Reprinted as at Philippines) Order 1980 22 July 2004 Article 5—continued the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;

the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character.

A person acting in a Contracting State on behalf of an enter- prise of the other Contracting State (other than an agent of an independent status to whom paragraph 5 applies) shall be deemed to be a permanent establishment of that enterprise in the first-mentioned State if he has and habitually exercises in that State, an authority to conclude contracts on behalf of the enterprise, unless his activities are limited to the purchase of goods or merchandise for that enterprise.
An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of the enterprise, he shall not be considered as agent of an independent status within the meaning of this paragraph if the transactions between the agent and the enterprise were not made under arms-length condi- tions. In such a case, the provisions of paragraph 4 shall apply.
The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other. 8

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1

Article 6 Income from immovable property

Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.
The term “immovable property” shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufrust of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property.
The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immov- able property.
The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to in- come from immovable property used for the performance of independent personal services.

Article 7 Business profits

The profits of an enterprise of one of the Contracting States shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a perman- ent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State, but only so much of them as is attributable to— (a) that permanent establishment; or (b) sales within that other Contracting State of goods or merchandise of the same or a similar kind as those being sold, or other business activities of the same or a similar 9

Schedule 1 Double Taxation Relief (Republic of the Reprinted as at Philippines) Order 1980 22 July 2004 Article 7—continued kind as those being carried on through that permanent establishment if the sale or the business activities had been made or carried on in that way with a view to avoiding taxation in that other State.

Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.
In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including execu- tive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.
Insofar as it has been customary in a Contracting State to de- termine the profits to be attributed to a permanent establish- ment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.
Notwithstanding the provisions of paragraph 3, no deduction shall be allowed in respect of amounts paid or charged (other than reimbursement of actual expenses) by the permanent es- tablishment to the head office of the enterprise or any of its other offices, by way of: 10 (a) royalties, fees or other similar payments in return for the use of patents or other rights; (b) commission for specific services performed or for man- agement; and

Reprinted as at 22 July 2004 (c) Double Taxation Relief (Republic of the Philippines) Order 1980 Schedule 1 Article 7—continued

interest or money lent to the permanent establishment, except in the case of a banking institution.

No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provi- sions of those Articles shall not be affected by the provisions of this Article. Article 8 Shipping and air transport
Profits derived by an enterprise of a Contracting State from the operation in international traffic of ships or aircraft shall be taxable in that State.
Notwithstanding the provisions of paragraph 1, profits from sources within a Contracting State derived by an enterprise of the other Contracting State from the operation of ships or aircraft in international traffic may be taxed in the first-men- tioned State but the tax so charged shall not exceed one and one-half percent of the gross revenues derived from sources in that State.
The provisions of paragraphs 1 and 2 shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency. Article 9 Associated enterprises Where (a) an enterprise of a Contracting State participates directly or in- directly in the management, control or capital of an enterprise of the other Contracting State, or 11

Double Taxation Relief (Republic of the Reprinted as at Schedule 1 Philippines) Order 1980 22 July 2004 Article 9—continued (b) the same persons participate directly or indirectly in the man- agement, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Article 10 Dividends

Dividends paid by a company which is a resident of a Con- tracting State to a resident of the other Contracting State may be taxed in that other State.
However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: (a) 15 percent of the gross amount of the dividends if the beneficial owner is a company; (b) 25 percent of the gross amount of the dividends in all other cases. The competent authorities of the Contracting State shall by mutual agreement settle the mode of application of these limi- tations.

This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.

The term “dividends” as used in this Article means income from shares and other income assimilated to income from shares by the taxation law of the Contracting State of which the company making the distribution is a resident.
The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Con- 12

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1

Article 10—continued

tracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or per- forms in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such per- manent establishment or fixed base. In such a case, the provi- sions of Article 7 or Article 14 as the case may be, shall apply.

Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State.
Nothing in this Convention shall be construed as preventing the Philippines from imposing on the earnings of a company attributable to a permanent establishment in that State, tax in addition to the tax which would be chargeable on the earn- ings of a company which is a resident of that State, provided that any additional tax so imposed shall not exceed 15 percent of the amount remitted abroad. For the purpose of this pro- vision, the term “earnings” means the profits attributable to a permanent establishment in the Philippines in a year and pre- vious years after deducting therefrom all taxes, other than the additional tax referred to herein, imposed on such profits by that State.

Article 11 Interest

Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 13

Double Taxation Relief (Republic of the Reprinted as at Schedule 1 Philippines) Order 1980 22 July 2004 Article 11—continued

However, such interest may also be taxed in the Contracting State in which it arises, and according to the law of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 15 percent of the gross amount of the interest. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.
The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mort- gage, and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government se- curities and income from bonds or debentures, including pre- miums and prizes attaching to such securities, bonds or deben- tures, as well as income assimilated to income from money lent by the taxation law of the State in which the income arises, in- cluding interest on deferred payment sales. Penalty charges for late payment shall not be regarded as interest for the pur- pose of this Article.
The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest, being a resident of a Contract- ing State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effect- ively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.
Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local au- thority or a resident of that State. Where, however, the person paying the interest whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establish- ment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred; and such interest is borne by such permanent establishment or fixed base, then 14

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1

Article 11—continued such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.

Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.
Interest derived by the Government of a Contracting State, or by any other body exercising governmental functions in, or in a part of, a Contracting State, or by a bank performing central banking functions in a Contracting State, shall be exempt from tax in the other Contracting State.
The Philippine tax on interest arising in the Philippines in re- spect of public issues of bonds, debentures or similar obliga- tions and paid by a company which is a resident of the Philip- pines to a resident of New Zealand shall not exceed 10 percent of the gross amount of the interest.

Article 12 Royalties

Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
However, such royalties may also be taxed in the Contracting State in which they arise, and according to the law of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed:

(a) in the case of New Zealand, 15 percent of the gross amount of the royalties; and (b) in the case of the Philippines, (i) 15 percent of the gross amount of the royalties where the royalties are paid by an enterprise 15

Schedule 1 (ii) Double Taxation Relief (Republic of the Reprinted as at Philippines) Order 1980 22 July 2004

Article 12—continued registered with the Philippine Board of In- vestments and engaged in preferred areas of activities; and in all other cases, 25 percent of the gross amount of the royalties.

The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.

The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, com- mercial or scientific equipment, or, for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on films or video tapes for use in connection with tele- vision or tapes for use in connection with radio broadcasting.
The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Con- tracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent estab- lishment situated therein, or performs in that other State inde- pendent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establish- ment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local au- thority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establish- ment or a fixed base in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royal- 16

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1

Article 12—continued ties shall be deemed to arise in the State in which the perman- ent establishment or fixed base is situated.

Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.

Article 13 Alienation of property

Income or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Art- icle 6, and situated in the other Contracting State may be taxed in that other State.
Income or gains from the alienation of movable property form- ing part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Con- tracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Con- tracting State for the purpose of performing independent per- sonal services, including such income or gains from the alien- ation of such permanent establishment (alone or together with the whole enterprise) or such fixed base, may be taxed in that other State.
Income or gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State.
Income or gains from the alienation of any property, other than those mentioned in this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

Article 14 Independent personal services

Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State unless such ser- vices are performed in the other Contracting State, and (a) the individual is present in the other State for a period or periods exceeding in the aggregate 183 days in the year of income or fiscal year, as the case may be, for the purpose of performing his activities, or (b) the individual has a fixed base regularly available to him in the other State for the purpose of performing his activities.

In such cases, the income may be taxed in that other State but only so much of it as is attributable to activities connected with that fixed base or performed during such period or periods.

Notwithstanding paragraph 1 of this Article income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character may be taxed in the other Contracting State if the gross remuneration derived for his services in the year of income or fiscal year from residents of the other State exceeds eleven thousand New Zealand dollars or its equivalent in Philippine pesos or such other amount as may be specified and agreed in letters exchanged between the competent authorities of the Contract- ing States.
The term “professional services” includes, especially, inde- pendent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. 18

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 1 Article 15 Dependent personal services

Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other similar remuneration derived by an individual who is a resident of one of the Contracting States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
Notwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a resident of one of the Con- tracting States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-men- tioned State if— (a) the recipient is present in that other State for a period or periods not exceeding in the aggregate 183 days in the year of income or fiscal year, as the case may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of that other State; and (c) the remuneration is not deductible in determining the taxable profits of a permanent establishment or a fixed base which the employer has in that other State.
Notwithstanding the preceding provisions of this Article, re- muneration in respect of an employement exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in that Contracting State.

Article 16 Directors’ fees

Directors’ fees and other similar payments derived by a resi- dent of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State, may be taxed in that other State.
The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 15.

Article 17 Artistes and athletes

Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State may be taxed in that other State.
Where income in respect of personal activities exercised by an entertainer or athlete in his capacity as such accrues not to that entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.
The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed in a Contracting State by an entertainer or an athlete if the visit to that Contracting State is substantially supported by the public funds of the other Contracting State, including those of any political subdivision, local authority or statutory body thereof, nor to income derived by a non-profit making organization in respect of such activities provided no part of its income is payable to, or is otherwise available for the personal benefit of its proprietors, members or shareholders and the organisation is certified as qualifying under this provision by the competent authority of the other State.

Article 18 Pensions and annuities

Subject to the provisions of paragraph 2 of Article 19, pensions and annuities paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.
Notwithstanding the provisions of paragraph 1, social secur- ity pensions paid by a social security system of a Contracting State shall be taxable only in that Contracting State.
(a) The term “pensions” as used in this Article means peri- odic payments made in consideration for past services rendered.
(a) Article 19 Government service Remuneration, other than a pension, paid by a Contract- ing State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
(a) (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services.

Any pension paid by, or out of funds created by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. (b) The term “annuity” as used in this Article means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.

(b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who:

(b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

The provisions of Articles 15, 16, and 18 shall apply to remu- neration and pensions in respect of services rendered in con- nection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

Article 20 Professors and teachers

Remuneration which a professor or teacher who is a resident of one of the Contracting States and who visits the other Contracting State for a period not exceeding two years for the pur- pose of teaching or carrying out advanced study or research at a university, college, school or other educational institution, receives for those activities shall be taxable only in the first-mentioned State.
This Article shall not apply to remuneration which a professor or teacher receives for conducting research if the research is undertaken primarily for the private benefit of a specific person or persons.
For the purposes of paragraph 1 of this Article, the term re- muneration shall include remittances from sources outside the other State sent to enable the professor or teacher to carry out the purposes referred to in paragraph 1.

Article 21 Students and trainees

An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that Contracting State solely as a student at a university, college or other similar educational institution or as a business apprentice, or as a trainee for the purpose of acquiring technical professional or business experience, shall, from the date of his first arrival in that Contracting State in connection with that visit be exempt from tax in that Contract- ing State on all remittances from abroad for the purposes of his maintenance, education or training.
An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that Contracting State solely for the purpose of study, research or training as a recipient of a grant, allowance or award from an arrangement or assistance programme entered into by the Government of a Contracting State shall be exempt from tax in that Contracting State on

(a) the amount of such grant, allowance or award; and

(b) all remittances from abroad for the purposes of his main- tenance, education or training.

Article 22 Other income Items of income of a resident of a Contracting State which are not ex- pressly mentioned in the foregoing Articles of this Convention shall be taxable only in that Contracting State except that, if such income is derived from sources within the other Contracting State, it may also be taxed in accordance with the law of that other State.

Article 23 Relief from double taxation Double taxation shall be avoided in the following manner: 1. In the case of the Philippines: Subject to the provisions of the laws of the Philippines relat- ing to the allowance as credit against Philippine tax of taxes paid in a territory outside the Philippines, New Zealand taxes paid or which have accrued under the laws of New Zealand and in accordance with this Convention, whether directly or by deduction, in respect of income from sources within New Zealand shall be allowed, where similar tax is imposed in the Philippines, as a credit against Philippine tax payable in re- spect of that income. The deduction shall not, however, exceed that part of the Philippine income tax, as computed before the deduction is given, which is appropriate to the income which may be taxed in New Zealand.

In the case of New Zealand:

Subject to any provisions of the law of New Zealand which may from time to time be in force and which relate to the al- lowance of a credit against New Zealand tax of tax paid in a country outside New Zealand (which shall not affect the gen- eral principle hereof), Philippine tax paid under the law of the Philippines and consistently with this Convention, whether di- rectly or by deduction, in respect of income derived by a New Zealand resident from sources in the Philippines (excluding, in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid) shall be allowed as a credit against New Zealand tax payable in respect of that income.

Dividends derived by a company which is a resident of New Zealand from a company which is a resident of the Philippines (being dividends which, in accordance with the taxation law of New Zealand in existence at the date of signature of this convention, would be exempt from New Zealand tax) shall be exempt from New Zealand tax. Where, in terms of paragraph 2(b)(i) of Article 12, a resident of New Zealand derives income from royalties which are paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activity he shall be deemed to have paid in addition to the Philippine tax actually paid, Philippine tax in an amount equal to 10 percent of the gross amount of the royalties.

For the purposes of this Article, profits, income or gains of a resident of New Zealand which are taxed in the Philippines in accordance with the Convention shall be deemed to arise from sources in the Philippines.

Article 24 Mutual agreement procedure

Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, without prejudice to the remedies provided by the national laws of those States, address to the competent authority of the Contracting State of which he is a resident, an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the Convention.
The competent authority shall endeavour, if the objection ap- pears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Convention.
A Contracting State shall not, after five years from the end of the taxable period in which the income concerned has ac- crued, increase the taxable income of a resident of either of the Contracting States by including therein items of income which have also been charged to tax in the other Contracting State. This paragraph shall not apply in the case of fraud, wilful default or neglect.
The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimin- ation of double taxation in cases not provided for in this Con- vention.
The competent authorities of the Contracting States may com- municate with each other directly for the purpose of giving effect to the provisions of the Convention. Article 25 Exchange of information
The competent authorities of the Contracting States shall ex- change such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Conven- tion insofar as the taxation thereunder is not contrary to the Convention, as well as to prevent fiscal evasion. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or author- ities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in ju- dicial decisions.
In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation:

(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;

(b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

Article 26 Territorial extension

This Convention may be extended, either in its entirety or with any necessary modifications, to any territory for whose inter- national relations New Zealand is responsible, which imposes taxes substantially similar in character to those to which the Convention applies. Any such extension shall take effect from such date and subject to such modifications and conditions (including conditions as to termination) as may be specified and agreed between the Contracting States in notes to be ex- changed through diplomatic channels or in any manner in accordance with their constitutional procedures.
Unless otherwise agreed by both Contracting States, the termination of the Convention by one of them under Article 29 shall also terminate, in the manner provided for in that Article, the application of the Convention to any territory to which it has been extended under this Article.
Paragraph 4 of Article 2 shall apply to any taxes imposed by any territory to which the Convention is extended under this Article.

Article 27 Diplomatic and consular officers Nothing in this Convention shall affect the fiscal privileges of diplo- matic and consular officials under the general rules of international law or under the provisions of special international agreements.

Article 28 Entry into force

This Convention shall be ratified and the instruments of ratifi- cation shall be exchanged at Manila as soon as possible.
The Convention shall enter into force upon the exchange of the instruments of ratification and its provisions shall have effect:

(a) in the Philippines: (i) in respect of tax withheld at the source on amounts paid to non-residents on or after the first day of January in the calendar year in which the exchange of instruments of ratification takes place; and (ii) in respect of other taxes for taxation years begin- ning on or after the first day of January in the calendar year in which the exchange of instruments of ratification takes place;

(b) in New Zealand:

in respect of income assessable for any income year be- ginning on or after 1 April in the calendar year in which the exchange of instruments of ratification takes place. 27

Double Taxation Relief (Republic of the Reprinted as at Schedule 1 Philippines) Order 1980 22 July 2004

Article 29 Termination

This Convention shall continue in effect indefinitely but either Contracting State may, on or before June 30 in any calendar year after the fifth year following the exchange of the instru- ments of ratification, give notice of termination to the other Contracting State and in such event the Convention shall cease to have effect:

(a) in the Philippines: (i) in respect of tax withheld at the source on amounts paid to non-residents on or after the first day of January in the calendar year next following that in which the notice of termination is given; and (ii) in respect of other taxes for taxation years begin- ning on or after the first day of January in the cal- endar year next following that in which the notice of termination is given:

(b) in New Zealand: in respect of income assessable for any income year be- ginning on or after 1 April in the calendar year immedi- ately following that in which the notice of termination is given.

Done in duplicate at Manila this 29th day of April 1980 in the English language. For the Government of New Zealand Hugh Templeton For the Government of the Republic of the Philippines Cesar Virata

Protocol At the time of signature of the Convention between the Govern- ment of the Republic of the Philippines and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions.

With reference to Article 2: (a) for the purposes of sub-paragraph (a) of paragraph 3 the New Zealand income tax does not include the bonus issue tax;

(b) the terms “Philippine tax” and “New Zealand tax” do not include any amount which represents a penalty or interest imposed under the law of either Contracting State relating to the taxes to which the Convention ap- plies.

With reference to Articles 7 and 22 it is understood that noth- ing in the Convention shall affect the operation of any law of a State relating to the taxation of income from any insurance business provided that if the relevant law in force in either State at the date of signature of the Convention is amended (otherwise than in minor respects so as not to affect its general character) the States shall consult with each other with a view to agreeing to any amendment of this paragraph that may be appropriate. It is also understood that rental income derived from the lease of ships, aircraft, machinery or equipment will, for the purpose of the Convention, be regarded as “other in- come” and subject to the provisions of Article 22.
With reference to Article 8 if at any time after the date of sig- nature of the Convention the Philippines agrees to a lower or nil rate of tax with a third state the Government of the Republic of the Philippines shall without undue delay inform the Government of New Zealand through diplomatic channels and the two Governments will undertake to review this Article with a view to providing such lower or nil rate to profits of the same kind derived under similar circumstances by enterprises of both Contracting States.
With reference to paragraph 5 of Article 10, the expression “tax on the company’s undistributed profits” shall not include the bonus issue tax referred to in paragraph 1(a) of this Protocol.
With reference to Articles 10, 11 and 12, dividends, interest or royalties in respect of which a trustee is subject to tax in New Zealand may be treated as being beneficially owned by that trustee.
With reference to Article 12, the term royalties as defined shall in any case include other like payments which are dependent upon production, sales, performance, results or any other similar basis.
With reference to Article 13, gains from the alienation of shares of a company, the property of which consists princi- pally of immovable property situated in a Contracting State, may be taxed in that State. Gains from the alienation of an in- terest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State.
If, at any time after the date of signature of the Convention, New Zealand shall include a non-discrimination Article in any of its double tax conventions, the Government of New Zealand shall without undue delay inform the Government of the Re- public of the Philippines in writing through diplomatic chan- nels and shall enter into negotiations with the Government of the Republic of the Philippines with a view to including a non-discrimination Article in the Convention.
The provisions of the Convention shall not be construed to restrict in any manner any exclusion, exemption, deduction, credit or other allowance now or hereafter accorded: (a) by the laws of one of the Contracting States in the deter- mination of the tax imposed by that Contracting State; or (b) by any other agreement entered into by a Contracting State. In witness whereof, the undersigned have signed the present Protocol which shall have the same force and validity as if it were inserted word by word in the Convention. Done at Manila this 29th day of April 1980 in duplicate, in the English language. For the Government of New Zealand Hugh Templeton

For the Government of the Republic of the Philippines Cesar Virata

Double Taxation Relief (Republic of the Reprinted as at Schedule 2 Philippines) Order 1980

Schedule 2 Protocol amending the Convention 22 July 2004 between the Government of New Zealand and the Government of the Republic of the Philippines for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Schedule 2: added, on 22 July 2004, by clause 5 of the Double Taxation Relief (Republic of the Philippines) Amendment Order 2004 (SR 2004/180).

The Government of New Zealand and the Government of the Repub- lic of the Philippines, Desiring that the Convention between the Government of New Zealand and the Government of the Republic of the Philippines for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with Protocol, signed at Manila on the 29th day of April 1980, be amended by both Contracting States, Have agreed that the following provisions shall be integrated into the Convention:

Article I An additional paragraph 2 shall be inserted in Article 9 (Associated Enterprises) of the Convention: “2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which might have been expected to have accrued to the enter- prise of the first-mentioned State if the conditions made be- tween the two enterprises had been those which might have been expected to have been made between independent enter- prises, then that other State shall make an appropriate adjust- ment to the amount of the tax charged therein on those profits.

In determining such adjustment, due regard shall be had to the other provisions of this Convention and the competent author- ities of the Contracting States shall if necessary consult each other.”

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Schedule 2

Article II Paragraph 2 of Article 10 (Dividends) of the Convention shall be deleted and replaced by the following:

“2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the law of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed 15 percent of the gross amount of the dividends.

This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.”

Article III Paragraph 2 of Article 11 (Interest) of the Convention shall be deleted and replaced by the following:

“2. However, such interest may also be taxed in the Contracting State in which it arises, and according to the law of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 10 percent of the gross amount of the interest.”

Article IV Paragraphs 2 and 3 of Article 12 (Royalties) of the Convention shall be deleted and replaced by the following:

“2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the law of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 15 percent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments or credits of any kind received as a consideration for:

(a) the use of, or the right to use, any copyright (including the use of or the right to use any literary, artistic or scientific work, any data or images, or any films, tapes or other medium used for storing data), patent, design or model, plan, secret formula or process, trademark, or other like property or right;

(b) the use of, or the right to use, any industrial, commercial or scientific equipment;

the supply of scientific, technical, industrial or commercial knowledge or information;

the supply of any assistance that is ancillary and subsidiary to, and is furnished as a means of enabling the application or enjoyment of, any such property or right as is mentioned in sub-paragraph (a), any such equipment as is mentioned in sub-paragraph (b) or any such knowledge or information as is mentioned in sub-para- graph (c);

total or partial forbearance in respect of the use or sup- ply of any property or right referred to in this para- graph.”

Article V Paragraph 2 of Article 23 (Relief from Double Taxation) of the Convention shall be deleted and replaced by the following: “2. In the case of New Zealand:

Subject to any provisions of the law of New Zealand which may from time to time be in force and which relate to the allowance of a credit against New Zealand tax of tax paid in a country outside New Zealand (which shall not affect the general principle thereof), Philippine tax paid under the laws of the Philippines and consistently with this Convention, whether directly or by deduction, in respect of income derived by a New Zealand resident from sources in the Philippines (excluding, in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid) shall be allowed as a credit against New Zealand tax payable in respect of that income.”

Article VI The taxes covered in this Protocol shall apply to income derived on or after the sixtieth day following that in which the Protocol enters into force.

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Article VII

The Contracting States shall notify each other in writing through diplomatic channels that the constitutional requirements for the entry into force of this Protocol have been complied with.
This Protocol shall enter into force on the date of the later of the notifications referred to in paragraph 1 of this Article.

IN WITNESS WHEREOF, the undersigned duly authorised thereto by their respective Governments, have signed this Protocol.

DONE at Wellington this 21st day of February 2002 in duplicate in the English language. For the Government of New For the Government of the Republic Zealand of the Philippines A C McLeod, Acting for Clerk of the Executive Council. Issued under the authority of the Acts and Regulations Publication Act 1989. Date of notification in Gazette: 23 October 1980.

Double Taxation Relief (Republic of the Notes Philippines) Order 1980 Contents Reprinted as at 22 July 2004 1 General 2 Status of reprints 3 How reprints are prepared 4 Changes made under section 17C of the Acts and Regulations Publication Act 1989 5 List of amendments incorporated in this reprint (most recent first) Notes 1 General This is a reprint of the Double Taxation Relief (Republic of the Philippines) Order 1980. The reprint incorporates all the amendments to the order as at 22 July 2004, as specified in the list of amendments at the end of these notes.

Relevant provisions of any amending enactments that contain transitional, savings, or application provisions that cannot be compiled in the reprint are also included, after the principal enactment, in chronological order. For more information, see http://www.pco.parliament.govt.nz/reprints/.

2 Status of reprints Under section 16D of the Acts and Regulations Publication Act 1989, reprints are presumed to correctly state, as at the date of the reprint, the law enacted by the principal enactment and by the amendments to that enactment. This presumption applies even though editorial changes authorised by section 17C of the Acts and Regulations Publication Act 1989 have been made in the reprint. This presumption may be rebutted by producing the official volumes of statutes or statutory regulations in which the prin- cipal enactment and its amendments are contained.

3 How reprints are prepared 36 A number of editorial conventions are followed in the prep- aration of reprints. For example, the enacting words are not included in Acts, and provisions that are repealed or revoked

Reprinted as at Double Taxation Relief (Republic of the 22 July 2004 Philippines) Order 1980 Notes are omitted. For a detailed list of the editorial conventions, see http://www.pco.parliament.govt.nz/editorial-conventions/ or Part 8 of the Tables of New Zealand Acts and Ordinances and Statutory Regulations and Deemed Regulations in Force.

4 Changes made under section 17C of the Acts and Regulations Publication Act 1989 Section 17C of the Acts and Regulations Publication Act 1989 authorises the making of editorial changes in a reprint as set out in sections 17D and 17E of that Act so that, to the extent permitted, the format and style of the reprinted enactment is consistent with current legislative drafting practice.

Changes that would alter the effect of the legislation are not permitted. A new format of legislation was introduced on 1 January 2000. Changes to legislative drafting style have also been made since 1997, and are ongoing. To the extent permitted by section 17C of the Acts and Regulations Publication Act 1989, all legislation reprinted after 1 January 2000 is in the new format for legislation and reflects current drafting practice at the time of the reprint.

In outline, the editorial changes made in reprints under the au- thority of section 17C of the Acts and Regulations Publication Act 1989 are set out below, and they have been applied, where relevant, in the preparation of this reprint: • omission of unnecessary referential words (such as “of this section” and “of this Act”) • typeface and type size (Times Roman, generally in 11.5 point) • layout of provisions, including: • indentation • position of section headings (eg, the number and heading now appear above the section) • format of definitions (eg, the defined term now appears in bold type, without quotation marks) • format of dates (eg, a date formerly expressed as “the 1st day of January 1999” is now expressed as “1 January 1999”) 37

Notes Double Taxation Relief (Republic of the Reprinted as at Philippines) Order 1980 22 July 2004

• position of the date of assent (it now appears on the front page of each Act)

• punctuation (eg, colons are not used after definitions)

• Parts numbered with roman numerals are replaced with arabic numerals, and all cross-references are changed accordingly

• case and appearance of letters and words, including:

• format of headings (eg, headings where each word formerly appeared with an initial capital letter followed by small capital letters are amended so that the heading appears in bold, with only the first word (and any proper nouns) appearing with an initial capital letter)

• small capital letters in section and subsection references are now capital letters

• schedules are renumbered (eg, Schedule 1 replaces First Schedule), and all cross-references are changed accordingly

• running heads (the information that appears at the top of each page)

• format of two-column schedules of consequential amendments, and schedules of repeals (eg, they are rearranged into alphabetical order, rather than chrono- logical).

List of amendments incorporated in this reprint (most recent first) Double Taxation Relief (Republic of the Philippines) Amendment Order 2004 (SR 2004/180)

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