13 May 2014
The Commissioner of Internal Revenue (“CIR”) has issued Revenue Memorandum Circular (“RMC”) No. 37-2014 dated 8 May 2014 to circularize the agreement between the Government of the Republic of the Philippines and the Government of the State of Kuwait to avoid double taxation and to prevent fiscal evasion with respect to taxes on income (the “Agreement”).
The RMC informs that the tax treaty came into force on 22 April 2013 and pursuant to Article 28 thereof, the provisions on taxes on income shall apply to income derived or which accrued beginning 1 January 2014. The RMC further states that Tax Treaty Relief Applications (TTRA) invoking the Philippines-Kuwait Double Taxation Agreement should be filed with and addressed to the International Tax Affairs Division (ITAD) at Room 811, Bureau of Internal Revenue, National Office Building, Diliman, Quezon City. A Kuwaiti resident income earner or his authorized representative should file a duly accomplished BIR Form 0901 (Application for Relief for Double Taxation) with the required documents specified at the back of the form in accordance of RMO No. 72-2013.