Contracting State, the capital of which is wholly or partly owned or

controlled, directly or indirectly, by one or more residents of the other

Contracting State, shall not be subjected in the first-mentioned
Contracting State to any taxation or any requirement connected
therewith which is other or more burdensome than the taxation and
connected requirements to which other similar enterprises of that first-
mentioned State are or may be subjected.
5.  Notwithstanding the preceding provisions of this Article either
Contracting State may, in the promotion of necessary industry or
business, limit to its nationals the enjoyment of tax incentives granted
by it. However, if such tax incentives should be granted to the nationals
of any third state, the nationals of the other contracting state will also
enjoy these benefits.
ARTICLE 26
Mutual Agreement Procedure
1.  Where a person considers that the actions of one or both of
the Contracting States result or will result for him in taxation not in
accordance with the provisions of this Convention, he may, irrespective
of the remedies provided by the domestic laws of those States, present
his case to the competent authority of the Contracting State of which he
is a resident or, if his case comes under paragraph 1 of Articles 25
(Non-Discrimination), to that Contracting State of which he is a national.
The case must be presented within two years from the first notification
of the action which gives rise to taxation not in accordance with the
provisions of this Convention.
2.  The competent authority shall endeavour, if the objection
appears 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 which is not in accordance with this Convention.
3.  A Contracting State shall not, after five years from the date of
the actual filing of the annual return for the taxable period in which the
income concerned has accrued, increase the tax base 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, willful default or
neglect.
4.  The competent authorities of the Contracting States shall
endeavour by mutual agreement any difficulties or doubts arising as to
the interpretation or application of the Convention. They may also
consult together for the elimination of double taxation in cases not
provided for in this Convention.
ARTICLE 27
 Exchange of Information
1.  The competent authorities of the Contracting States shall
exchange such information as is necessary for carrying out the
provisions of the Convention or of the domestic laws of the Contracting
States concerning taxes covered by the Convention in so far as the
taxation thereunder is in accordance with the Convention, in particular
for the prevention of fraud or evasion of such taxes. The competent
authorities shall, through consultation, develop appropriate conditions,
methods and techniques concerning the matters respecting how such
exchange of information shall be made as well as exchanges of
information regarding avoidance of tax where appropriate. 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 authorities (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
but they may disclose the information in public court procedures or in
judicial decisions.
2.  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 or the 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.
ARTICLE 28
Diplomatic Agents and Consular Officers
Nothing in this Convention shall affect the fiscal privileges of
diplomatic agents and consular officers under the general rules of
international law or under the provisions of special agreements.
ARTICLE 29
Entry Into Force
 1.  This Convention shall be ratified and the instruments of
ratification shall be exchanged as soon as possible.
2.  The Convention shall enter into force upon the exchange of
the instruments of ratification and its provisions shall have effect:
a)  in respect of taxes withheld at source on
amounts paid to non-residents on or after the
sixtieth day following that on which the exchange of
instruments of ratification takes place; and
b)  in respect to other taxes for taxation years
beginning on or after the first day of January of the
calendar year in which the exchange of instruments
of ratification takes place.
ARTICLE 30
Termination
This Convention shall remain in force until terminated by a
Contracting State. Either Contracting State may, on or before June 30 in
any calendar year after the fifth year following the exchange of the
instruments of ratification, by giving notice of termination to the other
Contracting State and in such event the Convention shall cease to have
effect:
a)  in respect of taxes 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 is given; and
b)  in respect of other taxes for taxation years
beginning on or after the first day of January in the
calendar year next following that in which the notice
is given.
IN WITNESS WHEREOF, the undersigned, being, duly
authorized thereto, have signed the present Convention.
Done in duplicate at Manila, this 9th day of June one thousand
and nine hundred and ninety two, in the English and Hebrew
languages, both the text being equally authentic. In case of
divergence in interpretation, the English text shall prevail. 
cdasia

(SGD.) FOR THE GOVERNMENT OF THE

REPUBLIC OF THE PHILIPPINES
(SGD.) FOR THE GOVERNMENT OF THE
STATE OF ISRAEL
 (Convention Between the Governments of the Republic of the
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Philippines and of the State of Israel, RP - Israel, [June 9, 1992])