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Alexander Howden & Co., Ltd., Et Al. vs. Collector Of Internal Revenue 121 Phil. 579

ALExANDER HOWDEN & CO., LTD., H. G. CHESTER & OTHERS, ET AL., petitioners, vs. THE COLLECTOR (NOW COMMISSIONER) OF INTERNAL REVENUE, respondent.

G.R. No. L-19392 | 1965-04-14

D E C I S I O N 


BENGZON, J. P., J.: 

In 1950 the Commonwealth Insurance Co., a domestic corporation, entered into reinsurance contracts with 32 British insurance companies not engaged in trade or business in the Philippines, whereby the former agreed to cede to them a portion of the premiums on insurances on fire, marine and other risks it has underwritten in the Philippines. Alexander Howden & Co., Ltd., also a British corporation not engaged in business in this country, represented the aforesaid British insurance companies. The reinsurance contracts were prepared and signed by the foreign reinsurers in England and sent to...