Revocation of BIR Ruling DA(FIT-002) 054-2010 which subjected onshore income of FCDU/OBU to 5% GRT
BIR Ruling No. 51-2010
dated September 7, 2010
The Bureau of Internal Revenue (BIR) has revoked its previous ruling which subjected the onshore interest income to be derived by the foreign currency deposit units (FCDUs) from the 3-year and 5-year Multi-Currency Retail Treasury Bonds for Overseas Filipino Workers (rTBs) issued by the Bureau of Treasury to the 5% gross receipts tax, aside from the 10% final withholding tax.
The BIR now clarifies that the said previous ruling is contrary to the provisions of Republic Act No. 9294, which restored the exemption of FCDUs from all taxes on its foreign currency transactions, except for the 10% final withholding tax on onshore income. With the said amendment, the tax exemption enjoyed by FCDUs under the 1977 Tax Code was clearly restored, which includes exemption from the gross receipts tax.
Hence, the onshore interest income to be derived by FCDUs from the said rTBS issued by the Bureau of Treasury is exempt from the 5% gross receipts tax.
Please be advised accordingly.
- (April 20, 2016) BDB Law Managing Partner and CEO Atty. Benedicta Du-Baladad discusses the serious problem of high cost of complying with taxes and presents recommendations on how to lower it, in “Comprehensive Tax Reform Dialogue”, an event hosted by US
- BDB Law’s Senior Associate, Atty. Filamer D. Miguel joins Tax Management Association of the Phils. (TMAP).
- BDB Law Senior Associate Atty. Pierre Martin D. Reyes was one of the panelists on an impact assessment of individual income tax reduction on household consumption in the Philippines, a research by graduate students from University of Asia & Pacific (UA&P)
- We are pleased to invite you to the Philippine Chamber of Commerce and Industry (PCCI) Tax Forum on March 7, 2016, 1:00 - 5:00pm. BDB Law Senior Associate Atty. Pierre Martin D. Reyes, one of the speakers, will be discussing the latest court decisions.
- Du-Baladad and Associates (BDB Law) Managing Partner & CEO, Atty. Benedicta Du-Baladad was one of the speakers in ACPAPP General Membership Meeting.
- The signing of Memorandum of Agreement between the Management Association of the Philippines (MAP) and the 15th partner-in-mission, Du-Baladad and Associates Foundation Inc., for the Educated Marginalized Entrepreneurs Resource Generation Program.
- BDB Law Managing Partner Dick Du-Baladad facilitates forum on “Tracking ASEAN Integration” hosted by the Financial Executives of the Philippines (FINEX) last October 1, 2015. Part 1 of the forum is on Islamic banking while Part II is on credit informatio
- BDB Law Managing Partner and CEO Dick Du-Baladad was the moderator during the FINEX Week’s forum on “Competitiveness, Inclusive Growth and Sustainability”.
- (July 10, 2015) BDB Law Du-Baladad and Associates Host the "WTS 2015 Asia Pacific Tax Symposium" Held at Dusit Thani Manila
- (January 27, 2015) BDB Law’s Managing Partner, Dick Du-Baladad, was inducted as Governor of the Management Association of the Philippines (MAP). Inducting Officer is His Eminence Luis Antonio G. Cardinal Tagle. In photo are the 2015 Governors (L-R): Popo
- (January 13, 2015) BDB Law’s Managing Partner, Dick Du-Baladad, has been elected as a trustee of the FINEX Research and Development Foundation. She also took oath as the Chairperson of the Asean Economic Community (AEC) Committee of the Financial Executi
- Managing Partner and CEO Atty. Benedicta Du-Baladad attended the Business Group Representatives to the Press Conference on New VAT Refund Rule (RMC 54-2014) held last November 5, 2014.
- Managing Partner and CEO Atty. Benedicta Du-Baladad in Breakfast Dialogue with Sen. Sonny Angara on Tax Reforms last October 7, 2014
- BDB Law’s transfer pricing team attends a transfer pricing seminar conducted by Transfer Pricing Analyst (TPA) in Singapore last September 28-30, 2014.
- WTS News Release, September 2014 - An update on the conclusions of the first OECD deliverables with a webcast regarding BEPS 2014 developments.
- Atty. Benedicta Du-Baladad, Speaks at the PCCI MAP Joint Tax Forum at the Intercontinental Hotel-Manila on March 25, 2014
- Atty. Benedicta Du-Baladad, Managing Partner and CEO of Du-Baladad and Associates presented to Insurance Commissioner Emmanuel F. Dooc its newly published book entitled “Taxation of Insurance Companies in the Philippines”.
- BDB Law Partners and Associates
- Managing Partner Dick Du-Baladad speaks at a forum on Estate Tax Planning conducted by the Financial Executives of the Philippines (FINEX). September 11, 2013, Dusit Hotel, Makati City.
- WTS Singapore August 2013