Tax Alert No. 15 [Revenue Memorandum Circular (RMC) No. 30-2024 dated 23 February 2024]

Entry into Force, Effectivity, and Applicability of the Philippines-Brunei Double Taxation Agreement

Please be informed that RMC No. 30-2024 was issued to announce that the Agreement between the Government of the Republic of the Philippines and the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (PH-Brunei Tax Treaty) has entered into force on January 25, 2024.

The Agreement shall have effect on income derived from sources within the Philippines beginning January 1, 2025.

Tax Treaty Relief Applications or Requests for Confirmation invoking the provisions of the PH-Brunei Tax Treaty should be filed with, and addressed to, the International Tax Affairs Division. For this purpose, the concerned tax resident of Brunei, the income payor or withholding agent, or their duly authorized representative, should file a duly accomplished Application for Treaty Purposes (BIR Form No. 0901), together with the required documents, pursuant to Revenue Memorandum Order No. 14-2021, as clarified by RMC No. 77-2021.

You may access the full version of this issuance through the BIR website.

For any inquiry or request for assistance, please feel free to contact anyone from our Tax Services group. You may also reach us through this link.