OrbitaxPhilippine Court of Appeals Holds Tax Treaty Relief may Not be Denied based on Late Treaty Relief Application
|Approved Changes|Philippines
A decision of the Philippine Court of Tax Appeals was published 23 February 2017 concerning whether failure to timely file a Tax Treaty Relief Application (TTRA) is grounds for denying treaty relief.
The case involved Toyota Motor Philippines (Toyota P), which on 1 May 2009 entered into a technical assistance agreement granting license to manufacture certain series of motor vehicles and their…
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