Miscellaneous Topics

Topics

A. Corporate Recovery and Tax Incentives for Enterprises

(CREATE)
B. Local Government Taxation
A. Local Business Tax
B. Community Tax
C. Real Property Tax
C. Tariff and Customs Code
D. Documentary Stamp Tax
E. Double Tax Agreements
Corporate Recovery and Tax
Incentives for Enterprises
(CREATE)
1. Which of the following is not included in the term
‘corporation’ under Section 22 (B) of the Tax Code, as amended?

a. One person corporations

b. Joint-stock companies
c. Joint accounts
d. General professional partnerships
2. Upon effectivity of CREATE, winnings of a non-resident
alien engaged in trade or business (NRAETB) shall be subject to
a final tax of 20%, except for ______ which shall be exempt.
a. Philippine Charity Sweepstakes Office (PCSO) and Lotto
winnings, regardless of amount
b. Lotto winnings, regardless of amount
c. PCSO and Lotto winnings amounting to P10,000 or less
d. PCSO winnings amounting to P10,000 or less
Final Tax on Winnings of Individuals

RC/NRC/RA NRAETB NRAETB

P10,000 or less
from Philippine
Charity EXEMPT EXEMPT 25%
Sweepstakes and
Lotto
More than
P10,000 20% 20% 25%
Summary of Regular Corporate Income Tax Rates

Taxpayer Old Rate New Rate Effectivity

Domestic Corporations 30% 20% July 1, 2020

With net taxable income not exceeding P5M and total assets
(excluding land) not exceeding P100M

Domestic Corporations 30% 25% July 1, 2020

Resident Foreign Corporations 30% 25% July 1, 2020

Nonresident Foreign 30% 25% January 1,

Corporations 2021
3. For the year 2021, Mr. A, the sole stockholder of a one person
corporation, had total assets amounting to P50,000,000 and a
net taxable income of P10,000,000. The taxable income is
subject to
a. Graduated rates on individuals
b. 8% tax
c. 20% corporate income tax
d. 25% corporate income tax
Summary of Minimum Corporate Income Tax Rates

Taxpayer New Rate Effectivity

Domestic Corporations (MCIT) 1% July 1, 2020 until June 30,

2023
Resident Foreign Corporations 1% July 1, 2020 until June 30,
(MCIT) 2023
4. The minimum corporate income tax (MCIT) rate shall be one
percent (1%) of the gross income ____.

a. From January 1, 2020 onwards

b. From July 1, 2020 until July 31, 2023
c. Upon effectivity of CREATE and indefinitely
d. From July 1, 2020 until June 30, 2023
Illustration: Corporate Income Tax

A Corporation has the following data for calendar year 2020, its
6th year of business operations.

Gross sales 1,400,000,000 Total assets

Cost of sales 560,000,000 (including land) 180,000,000
Gross income 840,000,000 Land 50,000,000
Allowable deductions 150,000,000
Net taxable income 690,000,000

Determine the income tax payable of A Corporation.

Illustration: Corporate Income Tax

Determine the income tax payable of A Corporation.

Jan. 1 - June 30, 2020 (690*6/12*30%) 103,500,000

July 1 - Dec. 31, 2020 (690*6/12*25%) 86,250,000
RCIT 189,750,000

Jan. 1 - June 30, 2020 (840*6/12*2%) 8,400,000

July 1 - Dec. 31, 2020 (840*6/12*1%) 4,200,000
MCIT 12,600,000

Income Tax Payable (Higher between RCIT and MCIT) 189,750,000

Illustration: Corporate Income Tax

Alternative Computation

RCIT (690*27.5%) 189,750,000

MCIT (840*1.5%) 12,600,000

Income Tax Payable

(Higher between RCIT and MCIT) 189,750,000

Average Rates:
RCIT (30%+25%)/2
MCIT (2%+1%)/2
5. Taxable income of proprietary educational institutions and
hospitals whose gross income from unrelated activities exceed
50% of its total gross income is ___.

a. Subject to a preferential rate of 10% from July 1, 2020 until

June 30, 2023
b. Subject to a preferential rate of 1% from July 1, 2020 until
June 30, 2023
c. Subject to regular corporate income tax
d. Exempt from tax
6. Which of the following GOCCs is not exempt from income
tax upon effectivity of CREATE?

a. Government Service Insurance System (GSIS)

b. Social Security System (SSS)
c. Home Development Mutual Fund (HDMF)
d. Philippine Health Insurance Corporation (PHIC)
e. Local water districts (LWDs)
f. None of the above
7. The following are requirements for the exemption of foreign-
sourced dividends from income tax. Which is the exception?

a. The funds received are reinvested in the business

operations of the recipient within the next taxable year
from the time the dividends were received
b. The recipient is a domestic corporation.
c. The domestic corporation holds directly or indirectly at
least 20% of the shares of the foreign corporation for a
minimum of 2 years at the time of dividend distribution
d. None of the above
8. Upon effectivity of CREATE, interest income derived by
Offshore Banking Units (OBUs) derived from foreign currency
loans granted to residents
a. Shall be subject only to a final tax of 10%
b. Shall be subject to a regular corporate income tax of 20%
or 25%
c. Shall be subject to a regular corporate income tax of 25%
d. Shall be exempt from income tax
9. Beginning January 1, 2022, regional operating headquarters
shall pay a ____ tax on their taxable income

a. 1%
b. 10%
c. 20%
d. 25%
10. Upon effectivity of CREATE, Improperly Accumulated
Earnings Tax (IAET) will be reduced to one percent (1%)
a. True
b. False
11. A non-resident foreign corporation (NRFC) shall pay a tax
of ___ on its gross income effective ___

a. 20%; January 1, 2022

b. 25%; January 1, 2021
c. 20%; January 1, 2021
d. 25%; January 1, 2022
12. Upon effectivity of CREATE, the reduction to interest
expense shall be 20% of interest income subject to final tax

a. True
b. False
Illustration: Non-deductible Interest

Case A Case B
Calendar year CY 2021 CY 2021
Interest expense 400,000 400,000
Interest income subject to
20% final tax 125,000 125,000
Taxable income 6,500,000 4,500,000
RCIT 25% 20%
Tax Arbitrage Rate 20% 0%
Non-deductible interest 25,000 -
13. Upon effectivity of CREATE, additional deductions shall be
allowed to taxpayers equal to ____ of the value of the labor
training expenses for skills development of enterprise-based
trainees enrolled in public senior high schools and other
vocational institutions and those under an apprenticeship
agreement under PD 442.
a. 100%
b. 80%
c. 50%
d. 25%
Illustration: Additional Training Expense

Assume that Corporation A had the following data for the calendar year 2021:

Gross Sales 100,000,000 Operating Expenses

Cost of Sales Salaries and Wages 7,000,000
Direct Materials 30,000,000 Taxes 300,000
Direct Labor 20,000,000 Depreciation 3,500,000
Overhead 10,000,000 Professional Fees 200,000
Advertising 3,000,000
Total 60,000,000
Training Expenses 3,000,000
Office Supplies 500,000
Total 17,500,000
Illustration: Additional Training Expense

Gross Sales 100,000,000

Actual Training
Cost of Sales 60,000,000
Expense 3,000,000
Gross Income 40,000,000
Multiply by: 50%
Operating Expenses
Additional Training
Expense 1,500,000 Salaries and Wages 7,000,000
Taxes 300,000
Direct Labor 20,000,000 Depreciation 3,500,000
Multiply by: 10% Professional Fees 200,000
Limit 2,000,000 Advertising 3,000,000
Training Expenses 3,000,000
Office Supplies 500,000
Expenses before Additional Deduction 17,500,000
Additional Deduction 1,500,000
Net taxable income 21,000,000
14. Pursuant to CREATE, sale of reading materials covered by
the UNESCO agreement shall be VAT-exempt

a. If it is in physical format
b. If it is in digital or electronic format
c. Whether it is in physical, digital or electronic format
d. If the publication appears at regular intervals
15. From Jan. 1, 2021 to Dec. 31, 2023, sale or importation of
goods for COVID-19 prevention/treatment is VAT-exempt

a. True
b. False
15. From Jan. 1, 2021 to Dec. 31, 2023, sale or importation of
goods for COVID-19 prevention/treatment is VAT-exempt

a. True
b. False
16. Pursuant to CREATE, VAT-exemption on sale of drugs for
cancer, mental illness, tuberculosis etc. will start on

a. January 1, 2020
b. January 1, 2021
c. July 1, 2021
d. January 1, 2023
17. The OPT rate under Section 116 of the Tax Code, as
amended, shall be 1%, instead of 3%

a. From July 1, 2020 onwards

b. From January 1, 2021 onwards
c. From July 1, 2021 to June 30, 2023
d. From July 1, 2021 to December 31, 2023
18. A new Title called _____ was introduced by CREATE.

a. Tax Incentives
b. Fiscal Incentives
c. Fiscal Incentives Review Board
d. Tax Incentives Management and Transparency
18. A new Title called _____ was introduced by CREATE.

a. Tax Incentives
b. Fiscal Incentives
c. Fiscal Incentives Review Board
d. Tax Incentives Management and Transparency
19. Government entities created by law, executive order, decree
or other issuance, in charge of promoting investments, granting
and administering tax and non-tax incentives, and overseeing
the operations of economic zones and freeports in accordance
with their respective special laws.
a. Fiscal Incentives Review Board
b. Investment Promotion Agencies
c. Freeport zones
d. Export enterprise
20. It exercises policy making and oversight functions on the
administration and grant of tax incentives by the IPAs and
other government agencies administering tax incentives.
a. Bureau of Internal Revenue
b. Department of Finance
c. Fiscal Incentives Review Board
d. Department of Trade and Industry
Composition of the FIRB
Chairperson
• Secretary of Finance

Co-Chairperson
• Secretary of Trade and Industry

Members
• Executive Secretary of the Office of the President
• Secretary of Budget and Management
• Director General of the National Economic and Development
Authority
21. It refers to any individual, partnership, corporation,
Philippine branch of a foreign corporation, or other entity
organized and existing under Philippine laws and registered
with an IPA excluding certain service enterprises.
a. Registered business enterprise
b. Domestic market enterprise
c. Export enterprise
d. Freeport zone
Registered Business Enterprises (RBEs)
Export enterprise refers an RBE engaged in manufacturing, assembling
or processing activity and services such as
• information technology (IT) activities and
• business process outsourcing (BPO),
• and resulting in the direct exportation,
• and/or sale of its manufactured, assembled or processed product or
IT/BPO services to another registered export enterprise that will form
part of the final export product or export service of the latter, of at
least 70% of its total production or output.
Domestic market enterprise refers to an RBE other than an export
enterprise.
22. Which of the following service enterprises may qualify as a
registered business enterprises (RBEs)?

a. Customs brokerage
b. Janitorial services
c. Banking and other financial services
d. Export manufacturing entity
23. It contains the priority projects or activities that are included
in the Philippine Development Plan or its equivalent, or other
government programs, the scope and coverage of location and
industry tiers, and the terms and conditions on the grant of
enhanced deductions, as set forth in Section 300 of the Tax
Code, as amended
a. Investment Priority Plan
b. Incentives Priority Plan
c. Strategic Investment Priority Plan
d. Special Incentives Priority Plan
24. Under CREATE, the following types of tax incentives may
be granted to registered projects of activities:

a. Income tax holiday (ITH)

b. Enhanced deductions
c. Special corporate income tax (SCIT) of 5% of gross
income
d. All of the above
Sec. 294. Incentives.
Income Tax Holiday Special Corporate Enhanced Deductions
(ITH) Income Tax (SCIT) (ED)
5% tax based on gross
Subject to RCIT but
income in lieu of all
No income tax entitled to additional
national and local
deductions
taxes
Duty Exemption on VAT exemption on
importation of capital
equipment, raw materials
importation and VAT zero-
rating on local purchases
25. Enhanced deductions may be granted simultaneously with
SCIT.

a. True
b. False
26. Under CREATE, net operating loss of a registered project
or activity during the first ___ years from the start of
commercial operations may be carried over within the next ___
consecutive taxable years immediately following the year of such
loss.

a. Three, three
b. Three, five
c. Five, five
d. Five, three
27. The period of availment of a Registered Business Enterprise (RBE)
I
Export enterprise: ITH of 4-7 years followed by SCIT

II
Export enterprise: Regular Corporate Income Tax (RCIT)
with enhanced deductions for ten (10 years)
III
Domestic Market Enterprise under the SIPP: ITH of 4-7
years followed by RCIT with enhanced deductions for 5
years

a. I only c. I and III

b. I and II d. I, II and III
Period of Availment

ITH (4-7 years) SCIT

Export Enterprise
RCIT with enhanced
deductions (10 years)

Domestic Market RCIT with enhanced

ITH (4-7
Enterprise deductions (5
years)
(under the SIPP) years)
Factors to Consider
1. Type of RBE
a. Export Enterprise
b. Domestic Market Enterprise
2. Location
a. National Capital Region
b. Metropolitan areas or areas
contiguous and adjacent to the
NCR
c. All other areas
3. Industry
a. Tier I – activities with high
potential for job creation, activities
that generate value creation thru
innovation, etc.
b. Tier II – Activities that produce
supplies, parts, components, etc.
that are critical to industrial
development
c. Tier III – R&D, highly-technical
manufacturing, etc.
 Period of Availment
For Exporters For Domestic Market Activities
Tier I Tier II Tier III Tier I Tier II Tier III
NCR 4 years ITH 5 years ITH 6 years ITH NCR
4 years ITH 5 years ITH 6 years ITH
+10 years +10 years +10 years
+5 years ED +5 years ED +5 years ED
ED/SCIT ED/SCIT ED/SCIT

Metropolitan 5 years ITH 6 years ITH 7 years ITH Metropolitan

areas areas 5 years ITH 6 years ITH 7 years ITH
+10 years +10 years +10 years
+5 years ED +5 years ED +5 years ED
ED/SCIT ED/SCIT ED/SCIT

All other 6 years ITH 7 years ITH 7 years ITH All other
6 years ITH 7 years ITH 7 years ITH
areas +10 years +10 years +10 years areas +5 years ED +5 years ED +5 years ED
ED/SCIT ED/SCIT ED/SCIT
28. RBEs with incentives granted prior to the effectivity of the
Act shall be subject to the following rules, except

a. RBE with granted ITH are allowed to continue for the

remaining period of the ITH
b. RBE with granted ITH and entitled to 5% Gross Income
Tax (GIT) are allowed to avail of the 5% GIT for a period
of 10 years
c. RBE currently availing the 5% GIT is allowed to avail of
the 5% GIT for a period of 10 years
d. None of the above
Local Government Taxation
29. Which of the following is not a fundamental principle of
local government taxation?

a. It shall be uniform in each local government unit

b. It may prohibit or regulate trade.
c. It must be levied and collected only for public purposes
d. It must be based on the taxpayer’s ability to pay
30. The power to impose a tax, fee, or charge or to generate
revenue under this Code shall be exercised by the sanggunian of
the local government unit concerned through ____.
a. An ordinance
b. A bill
c. A memorandum
d. An executive order
31. Taxing power of local government units shall not extend to
the following taxes, except

a. Documentary stamp tax

b. Income tax on banks and other financial institutions
c. Taxes on business enterprises certified to by the Board of
Investments
d. Excise taxes on articles enumerated under the National
Internal Revenue Code.
32. What is the basis for the computation of local business tax?

a. Gross sales or receipts of the prior year

b. Gross sales or receipts of the current year
c. Net income of the current year
d. Net income of the prior year
33. The rates of taxes that the city may levy may exceed the
maximum rates allowed for the province or municipality by not
more than _______ except the rates of professional and
amusement taxes.
a. 10%
b. 25%
c. 30%
d. 50%
34. Which statement/s is/are correct?

I The tax period of all local taxes, fees and charges shall be the
fiscal year of the taxpayer, unless otherwise provided.
II All local taxes, fees, and charges shall accrue on the first (1st) day
of January of each year, unless otherwise provided.
III New taxes, fees or charges, or changes in the rates, shall accrue on
the first (1st) day of the quarter next following the effectivity of
the ordinance
IV
All local taxes, fees, and charges shall be paid within the first ten
(10) days of January or of each subsequent quarter

a. I and II c. III and IV

b. II and III d. I, II and IV
 35. The rates of taxes that the city may levy may exceed the
maximum rates allowed for the province or municipality by not
more than _______ except the rates of professional and
amusement taxes.
a. 10%
b. 25%
c. 30%
d. 50%
36. Retiring businesses are taxed based on ______.

a. Gross sales or receipts of the prior year

b. Gross sales or receipts of the current year
c. Net income of the current year
d. Net income of the prior year
37. Which of the following is not exempt from community tax?

a. Diplomatic representatives
b. Transient visitors whose stay in the Philippines does not
exceed 3 months
c. Consular representatives
d. Local government employees and officials
38. The civil remedies for the collection of local taxes, fees, or
charges, and related surcharges and interest resulting from
delinquency shall be:
a. Administrative action thru distraint or levy;
b. Judicial action
c. Either (a) or (b)
d. Either (a) or (b) or both
39. Which statement is correct?
I
Local taxes, fees, or charges shall be assessed within three
(3) years from the date they became due.

II
In case of fraud or intent to evade payment, the period
shall be ten (10) years from discovery.
III
Local taxes, fees, or charges may be collected within five (5)
years from the date of assessment by administrative or
judicial action.

a. I and II c. II and III

b. I and III d. I, II and III
 Who is liable to Community Tax?

Individuals Juridical Persons

• Inhabitant of the Philippines
• Eighteen (18) years of age or over
• Every corporation no
• Who has been matter how created or
– Regularly employed on a wage or salary
basis for at least 30 consecutive working organized, whether
days during any calendar year, or
– who is engaged in business or occupation, domestic or resident foreign,
or
– who owns real property with an aggregate
engaged in or doing
assessed value of One thousand pesos
(P1,000.00) or more, or business in the Philippines
– who is required by law to file an income
tax return
Community Tax
Individuals
• Basic tax of P5.00
• Additional tax of P1.00 for every
P1,000 of income but shall not exceed
P5,000
• In the case of husband and wife,
additional tax shall be based on
• Total property owned by them
• Total gross receipts/earnings
Juridical Persons
• Basic P500
• Additional tax: Maximum of P10,000
in accordance with the following
schedule:
o For every P5,000 of real property based on
real property tax declaration where real
property is located: P2.00
o For every P5,000 of gross receipts or
earnings – P2.00
40. Mr. A, an 18-year-old student earned P 5,000 from his
internship where he rendered services for half a month. How
much is his community tax?
a. P0
b. P 5.00
c. P 7.00
d. P 10.00
41. A Corporation, a non-resident foreign corporation, derived
income amounting to P5,000,000 from the Philippines. How
much is its community tax payable?
a. P0
b. P 500
c. P 2,500
d. P 10,000
42. Which of the following is a fundamental principal of real
property taxation?

a. Real property shall be classified for assessment purposes on

the basis of its intended use
b. Real property shall be appraised at its current and fair
market value
c. The appraisal, assessment, levy and collection of real
property tax may be delegated to private persons
d. All of the above
43. It is the term used by the Local Government Code for the act
or process of determining the value of property as of a specified
date for a specific purpose
a. Appraisal
b. Assessment
c. Reassessment
d. Valuation
44. It is the fair market value of the real property multiplied by
the assessment level. It is synonymous to taxable value

a. Depreciated value
b. Replacement or reproduction cost
c. Fair value
d. Assessment value
 45. The following properties are exempt from real property taxes:
I. Real property actually, directly and exclusively used for hospitals, cultural, or scientific
purposes
II. Real property owned and used by local water districts, and government-owned or
controlled corporations rendering essential public services in the supply and
distribution of water and/or generation and transmission of electric power
III.Charitable institutions, churches, parsonages or convents appurtenant thereto,
mosques, non-profit or religious cemeteries and all lands, buildings, and improvements
actually, directly, and exclusively used for religious, charitable or educational purposes
IV.All real property owned by duly registered cooperatives as provided for under R.A. No.
6938
V. Machinery and equipment used for pollution control and environmental protection

a. I and II c. III, IV and V

b. II and III d. I, II, III and IV
46. A city or a municipality within the Metropolitan Manila
Area may levy a real property tax at a rate not exceeding

a. ½ of 1%
b. 1%
c. 1.5%
d. 2%
47. In addition to the basic real property tax, a province, city or
municipality within the Metropolitan Manila Area may levy an
annual tax of ___ based on the assessed value of real property,
the proceeds of which shall accrue to the Special Education
Fund (SEF), and an additional tax of ___ based on the assessed
value of idle lands.
a. 1%, 2%
b. 2%, 1%
c. 1%, 5%
d. 2%, 5%
Summary of RPT Rates

Basic SEF Idle Max

Lands
Province 1% 1% 5% 7%
City or 2% 1% 5% 8%
municipality
within Metro
Manila
48. Which of the following may not be considered an ‘idle
land’?

a. Lands which have become idle by reason of force majeure,

civil disturbance, natural calamity
b. Land actually used for grazing
c. Agricultural lands planted to permanent or perennial crops
with at least fifty (50) trees to a hectare
d. All of the above
49. Mr. A owns land in the province. The area of the parcel of
land is 10 hectares and it is suitable for agricultural use.
However, only 3 hectares was utilized. The province may impose:
a. Basic real property tax only
b. Basic real property tax and an additional tax for the SEF
c. Tax on idle lands only
d. Basic real property tax, an additional tax for the SEF and
tax on idle lands
50. When does real property tax accrue?
a. On the first day of January
b. On the last day of January
c. On the 20th day of January
d. On the 10th of January
51. Which statement is incorrect concerning the payment of
real property tax?

a. Payments of real property taxes shall first be applied to

prior years delinquencies, interests, and penalties
b. It may be paid in four (4) equal installments
c. The first installment must be paid on or before the last
month following the end of the first quarter
d. LGUs may give up to a 20% discount for advance payment
of real property tax
 52. Where the real property tax assessment is erroneous, the
remedy of the property owner is:
a. To file a claim for refund in the Court of Tax Appeals if he has
paid the tax, within thirty (30) days from date of payment;
b. To file an appeal with the Provincial Board of Assessment
Appeals within thirty (30) days from receipt of the assessment;
c. To file an appeal with the Provincial Board of Assessment
Appeals within sixty (60) days from receipt of the assessment;
d. To file an appeal with the Provincial Board of Assessment
Appeals within sixty (60) days from receipt of the assessment
and playing the assessed tax under protest.
Documentary Stamp Tax
59. Which statement/s is/are correct?
I. DST is paid by the person making, signing, issuing,
accepting or transferring the documents. However, whenever
one party to the taxable documents enjoy exemption from
the tax, it is no longer subject to DST.
II. The Tax Code provides that the DST return and the tax due
shall be filed and paid within 10 days following the close of
the month when the taxable document was signed, issued,
accepted and transferred.
a. True, True c. False, False
b. True, False d. False, True
60. Which of the following is exempt from DST?

a. Bank deposit accounts without a fixed term or maturity

b. Transfer of property pursuant to Section 40 (C) (2)
c. Sale, barter or exchange of shares of stock listed and
traded through the local stock exchange
d. All of the above
61. Failure to pay DST shall produce the following effects,
except:
a. The contract cannot be notarized
b. The contract shall be invalidated
c. The contract shall be inadmissible in court
d. All of the above
62. Which is incorrect with respect to DST on original issue of
shares of stock?
a. Par value stocks: P2.00 on every P200 or fractional part of the
par value
b. No par value stocks: P2.00 on every P200 of the actual
consideration
c. Stock dividends: Not subject to DST
d. None of the above
63. The DST on debt instruments

a. P0.75 on each P200 or fractional part of the issue price

b. P1.00 on each P200 or fractional part of the issue price
c. P1.50 on each P200 or fractional part of the issue price
d. P2.00 on each P200 or fractional part of the issue price
64. The DST on debt instruments shall be computed without
regard to its term.
a. True
b. False
65. Which statement is incorrect with respect to DST on deeds
of sale, conveyance and donation of real property?
a. The DST shall be based on the contract price or the fair market
value, whichever is higher.
b. When one of the contracting parties is the Government, DST
shall be based on actual consideration.
c. A transfer of real property may be exempt from donor’s tax but
not DST
d. The DST shall be P15.00 if the value or consideration does not
exceed P1,000 and P15.00 for each additional P1,000 or
fractional part thereof, in excess of P1,000
Double Tax Agreements
66. In general, double tax agreements (tax treaties) are
applicable to
a. Value-added tax
b. Income tax
c. Documentary stamps tax
d. All of the above
67. Which is not an advantage of double tax agreements?

a. Prevents international double taxation

b. Prevents tax evasion
c. Promotes investments
d. None of the above
68. It refers to a fixed place of business through which the
business of an enterprise is wholly or partially carried on.
a. Branch
b. Domicile
c. Permanent establishment
d. Temporary establishment
Interpreting Tax
Treaties:
General Rules
69. Which of the following may be exempt from income tax in
one contracting state?
a. Business profits
b. Dividends
c. Interests
d. Royalties
 That in all things,
God will be glorified.