- RMC No. 5-2024 clarifies the tax treatment of cross-border services.
- It is based on the Supreme Court decision in Aces Philippines Cellular Satellite Corp. v. Commissioner of Internal Revenue.
- The decision states that satellite air time fee payments are subject to final withholding tax.
- The tax treatment requires determining the source of income and the situs of that source.
- RMC No. 5-2024 provides a framework for assessing final withholding tax and final withholding value added tax on nonresident foreign corporations.
Source: kpmg.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
