1.

Sources of Income

Income Test of Source of Income

Bank Deposits Location of Bank (W/N or W/O the Phil)
Interest Income
Other Interest Income Residence of DEBTOR
From DC Income WITHIN
From RFC or NRFC
Income WITHIN = If 50% or more of the Gross
Income of the foreign company (for the past 3
years) was derived from sources within the
Dividend Income Philippines.

Income WITHOUT = If less than 50% of the Gross

Income of the foreign company (for the past 3
years) was derived from sources within the
Philippines.
Service Income Place of Performance
Rent Income Location of Property
Royalty Income Place of Use of Intangible
Gain on Sale of Real Property Location of Property

GEN RULE Place of Sale

PRODUCED in whole PRODUCED in whole or in part WITHIN and SOLD

or in part WITHIN and WITHOUT or PRODUCED in whole or in part
SOLD WITHOUT WITHOUT and SOLD WITHIN are considered as
income derived PARTLY WITHIN and PARTLY
WITHOUT.
Gain on Sale of Personal
Property PURCHASED WITHIN PURCHASED WITHIN and SOLD WITHOUT or
and SOLD WITHOUT PURCHASED WITHOUT and SOLD WITHIN-INCOME
IS DERIVED FROM WHERE THE PERSONAL
PROPERTY IS SOLD.

EXCEPT: Sale of shares of stock in DC is always

income WITHIN NO MATTER WHERE IT IS SOLD.

Gain on sale of Domestic Shares of Stock Income WITHIN

2. Income Taxpayer
Tax Base (Taxable Passive
Income Taxpayer Income Capital Gains Tax Tax Credit
Source) Income
INDIVIDUAL TAXPAYER
Sec 24 (C) Sec 24 (D) Intercorporate
Within Without Sec 24 (A) Sec 24 (B) Tax Credit MCIT IAET BPRT
SALES OF SS SALES OF RP Dividend
RC YES YES NIT - Graduated Scale FWT FWT FWT Allowed
NRC (OCW) YES NO NIT - Graduated Scale FWT FWT FWT Not Allowed
RA YES NO NIT - Graduated Scale FWT FWT FWT Not Allowed NOT APPLICABLE
NRAETB YES NO NIT - Graduated Scale FWT FWT FWT Not Allowed
NRANETB YES NO GIT 25% FWT FWT Not Allowed
CORPORATE TAXPAYER
Sec 24 (C) Sec 24 (D) Intercorporate
Within Without Sec 24 (A) Sec 24 (B) Tax Credit MCIT IAET BPRT
SALES OF SS SALES OF RP Dividend
2% of Gross
DC YES YES NIT 30% FWT FWT FWT Allowed Exempt 10%
Income
N/A Cannot acquire 2% of Gross
RFC YES NO NIT 30% FWT FWT Not Allowed Exempt N/A 15%
Real Prop Income
N/A Cannot acquire
NRFC YES NO GIT 30% FWT Not Allowed 15% N/A N/A N/A
Real Prop