Professional Documents
Culture Documents
a. number and value of the subject shares of the seller as of the date of
sale;
b. seller's percentage of ownership as of the date of sale;
c. acquisition date(s) of the subject shares;
d. mode of acquisition of the subject shares, including dates of previous
transfers and parties involved in said transfers; and
e. buyer's percentage of ownership after the transfer of the subject shares.
e. Comparative Schedule of Comparative Schedule of Property, Plant &
Equipment Original copy of the comparative schedule duly certi ed by a
responsible o cer 1 of the Philippine corporation, of the "real property or
real property interest/s" of the domestic corporation, re ecting the
necessary adjustment for the period from the last audited nancial
statement to the date of the interim unaudited nancial statement
submitted under letter (f) of this Section, using the format and observing
the guidelines set forth in Part VII of BIR Form No. 0901-C.
f. Financial Statement
SECTION 19. Reporting. — The Chief, ITAD thru the ACIR, Legal Service shall
prepare a monthly report of signed and issued rulings, including a list of archived and
discontinued taxpayer transactions covered by a TTRA due every 10th day of the
following month following the format herein attached as Annex "D".
SECTION 20. Repealing Clause. — Any revenue issuance which is inconsistent
with this Order is deemed revoked, repealed, or modified accordingly.
SECTION 21. Effectivity. — This Order shall take effect immediately and shall
apply to tax treaty relief applications/requests for ruling led after the effectivity of this
Order.
ANNEX A
Sworn Statement
KNOW ALL MEN BY THESE PRESENTS:
I, _____________, in my capacity as ________________ of _____________, with business address
______________, do hereby certify that the (describe speci c transaction subject of the request
for treaty relief), is not under any of the following:
CD Technologies Asia, Inc. © 2019 cdasiaonline.com
1. Investigation or on-going audit;
2. Administrative protest;
3. Claim for refund or issuance of a tax credit certificate, judicial or administrative
protest;
4. Collection proceedings; or
5. Judicial appeal
This certi cation is being issued as a requisite in the application for tax treaty relief with the
International Tax Affairs Division of the Bureau of Internal Revenue. EIAHcC
IN WITNESS WHEREOF, I have signed this Certi cation on this _____ day of _______, 20____ in
___________.
(Notary Public)
ANNEX B
Notice of Submission of Documents
[DATE]
[COMPANY NAME/NAME OF FIRM OR REPRESENTATIVE]
[Address]
Attention: [Name of signatory to application/letter]
Gentlemen/Ladies:
This is to acknowledge receipt of your letter/application dated [date of letter or
application], on behalf of your client, [name of income earner] requesting con rmation of your
opinion that [nature of application/transaction] pursuant to Article [speci c article being
invoked] of the [Tax Treaty Agreement being invoked].
To facilitate the processing of the above application, please submit the following
documents:
1. [LIST OF MISSING DOCUMENTS]
Should you fail to submit the aforementioned documents [on or before a de ned date],
we shall consider to archive your tax treaty relief application (TTRA), without prejudice to your
filing of a new application.
At any time when documentary requirements are completed you may re- le the TTRA
reckoned from the date of the original TTRA ling. Please submit a photocopy of the earlier
archived TTRA together with all the necessary documents and we shall be glad to assist you.
Any inquiry on the processing and evaluation of the above application may be directed
to the case o cer [name of handling o ce] , or the undersigned at Tel. Nos. 9265729 &
9270022 and Fax No. 9263420. The docket for your request has been assigned [ITAD control
or reference number] which you may use in your follow-ups.
Very truly yours,
[Name of Signatory]
ANNEX C
CD Technologies Asia, Inc. © 2019 cdasiaonline.com
Notice of Tax Treaty Relief Application for Archiving
[Date]
[Company Name/Name of Firm Representing Filer]
[Address]
Attention: [Name of Signatory to Application]
Gentlemen :
This refers to your Tax Treaty Relief Application [TTRA] on behalf of [name of income
earner] for a con rmation of your opinion that [nature of transaction or nature of query],
pursuant to the [Tax treaty being invoked].
In our letter dated [date of notice for submission of requirements], we gave you until
[date of ITAD deadline to taxpayer] to comply with the submission of documents so we can
process your application . However, to date we have not yet received all the documents
necessary for the processing of your application; namely
1. [LIST OF UNSUBMITTED DOCUMENTS]
In view thereof, we have already archived your le without prejudice to your
submission of the above requested documents to complete your TTRA.
At any time when documentary requirements are completed you may re- le the TTRA
reckoned from the date of original the TTRA ling. Please submit a photocopy of the earlier
archived TTRA together with all the necessary documents and we shall be glad to assist you.
HSTAcI
ANNEX D
INTERNATIONAL TAX AFFAIRS DIVISION
TAX TREATY RELIEF APPLICATIONS
ISSUED TAX TREATY RELIEF RULINGS
Ruling Filing Type
Tax Preferential
Date Income Income Nature of Case
No. (Original/
Identification Rate
Previously
No. of
Issued Payor Earner Confirmed
Archived)
Income
Payor
_________ ________ __________________ ___________ __________ ________ _______________ _____________
_________ ________ __________________ ___________ __________ ________ _______________ _____________
_________ ________ __________________ ___________ __________ ________ _______________ _____________
_________ ________ __________________ ___________ __________ ________ _______________ _____________
_________ ________ __________________ ___________ __________ ________ _______________ _____________
TTRAs ARCHIVED
TTRA Tax Identification Income Income Nature of Date
Date Filed
Filing No. of Payor Earner Case Archived
Reference Income Payor
__________ ___________ ___________________ ____________ ____________ ______________ _____________
__________ ___________ ___________________ ____________ ____________ ______________ _____________
__________ ___________ ___________________ ____________ ____________ ______________ _____________
__________ ___________ ___________________ ____________ ____________ ______________ _____________
__________ ___________ ___________________ ____________ ____________ ______________ _____________
CD Technologies Asia, Inc. © 2019 cdasiaonline.com
TTRAs DISCONTINUED
TTRA Tax Identification Income Income Nature of Reason not
Date Filed
Filing No. of Payor Earner Case pursued
Reference Income Payor by taxpayer
__________ ___________ ___________________ ____________ ____________ ______________ _______________
__________ ___________ ___________________ ____________ ____________ ______________ _______________
__________ ___________ ___________________ ____________ ____________ ______________ _______________
__________ ___________ ___________________ ____________ ____________ ______________ _______________
__________ ___________ ___________________ ____________ ____________ ______________ _______________