Tax Treaty Royalties and Most-Favored-Nation Clause

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REVENUE MEMORANDUM CIRCULAR NO. 46-2002, SEPTEMBER 2, 2002: Tax Treaty Royalties & Most-Favored-Nation Clause

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Title Source: Supreme Court: Tax Treaty Royalties and Most-Favored-Nation Clause

Law: Revenue Memorandum Circular No. 46-2002, September 2, 2002

Decision Date: Sep 2, 2002

This circular clarifies the tax implications of royalties under the RP-China tax treaty, establishing that royalties paid to US residents can be taxed at a maximum rate of 10% if they meet specific conditions, including approval by Philippine authorities.

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