14 March 2014
The Commissioner of Internal Revenue (“CIR”) has issued Revenue Memorandum Circular (“RMC”) No. 16-2014 dated 14 March 2014 to circularize the agreement between the Government of the Republic of the Philippines and the Government of the State of the Federal Republic of Nigeria to avoid double taxation and to prevent fiscal evasion with respect to taxes on income and capital gains (the “Agreement”).
Under this RMC, Tax Treaty Relief Applications (TTRA) invoking the Philippines-Nigeria Double Taxation Agreement should be filed with and addressed to the International Tax Affairs Division (ITAD) of the Bureau of Internal Revenue (BIR). A Nigerian resident income earner or his authorized representative should file a duly accomplished BIR Form 0901 with the required documents specified at the back of the BIR Form.
This provision on taxes on income of the Agreement is applicable on income derived or which accrued beginning 01 January 2014.