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ITAD Ruling No. 145-02 (service fees not treated as royalties)

ITAD Ruling No. 145-02 (service fees not treated as royalties)

ITAD RULING NO. 145-02 | 2002-08-21

August 21, 2002
 
ITAD RULING NO. 145-02
 
Section 42 (A) (4), Section 28 (B) (1) and
Section 108 (A) of the NIRC of 1997
DA 076-99
 
Follosco Morallos & Herce
Suite 1506, 15th Floor, 88 Corporate Center
141 Valero Street Corner Sedeño Street
Salcedo Village, Makati City 1229
 
Attention: Atty. Rachel P. Follosco
 
Gentlemen:
 
This refers to your letter dated February 7, 2001 to the Commissioner of Internal Revenue, which was forwarded to this Office by the Deputy Commissioner, Legal and Inspection Group on February 12, 2002, for and on behalf of your client, Oakwood Management Services (Philippines) Inc. (Oakwood...