The Supreme Court gave its decision on 19 August 2013 in the case of Deutsche Bank AG Manila Branch v. Commissioner of Internal Revenue (G.R. No. 188550). Details of the decision are summarized below.

(a) Facts. Deutsche Bank AG Manila Branch (DB Philippines) withheld 15% branch profit remittance tax (BPRT) on its regular banking unit net income remitted to Deutsche Bank Germany (DB Germany)…

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