Title II — TAX ON INCOME
tax payable by banks: Provided, however, That any interest income
derived from foreign currency loans granted to residents other than
offshore banking units or local commercial banks, including local
branches of foreign banks that may be authorized by the BSP to
transact business with offshore banking units, shall be subject only to
a final tax at the rate of ten percent (10%).
Any income of nonresidents, whether individuals or corporations,
from transactions with said offshore banking units shall be exempt
from income tax.
(5) Tax on Branch Profits Remittances. — Any profit remitted by a branch
to its head office shall be subject to a tax of fifteen percent (15%)
which shall be based on the total profits applied or earmarked for
remittance without any deduction for the tax component thereof
(except those activities which are registered with the Philippine
Economic Zone Authority). The tax shall be collected and paid in
the same manner as provided in Sections 57 and 58 of this Code:
Provided, That interests, dividends, rents, royalties, including
remuneration for technical services, salaries, wages, premiums,
annuities, emoluments or other fixed or determinable annual,
periodic or casual gains, profits, income and capital gains received
by a foreign corporation during each taxable year from all sources
within the Philippines shall not be treated as branch profits unless
the same are effectively connected with the conduct of its trade or
business in the Philippines.
(6) Regional or Area Headquarters and Regional Operating Headquarters
of Multinational Companies. —
(a) Regional or area headquarters as defined in Section 22(DD)
shall not be subject to income tax.
(b) Regional operating headquarters as defined in Section 22(EE)
shall pay a tax of ten percent (10%) of their taxable income.
(7) Tax on Certain Incomes Received by a Resident Foreign Corporation.—
(a) Interest from Deposits and Yield or any other Monetary Benefit
from Deposit Substitutes, Trust Funds and Similar Arrangements
and Royalties. — Interest from any currency bank deposit and
yield or any other monetary benefit from deposit substitutes and
from trust funds and similar arrangements and royalties derived
from sources within the Philippines shall be subject to a final
income tax at the rate of twenty percent (20%) of such interest:
Provided, however, That interest income derived by a resident
National Internal Revenue Code of 1997 (as amended by the TRAIN Law, RAs 11256, 11346 and 11467)
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