Beruflich Dokumente
Kultur Dokumente
NOTE
This digest was adjusted to meet our needs for the June 29
class.
RATIO DECIDENDI
Income of Filipino citizens temporarily residing in a foreign
country, even if totally derived from outside the Philippines, is
subject to tax by virtue of Sec. 21, NIRC, viz: A tax is hereby
imposed upon the taxable net income received x x x from all
sources by every individual, whether a citizen of the
Philippines residing therein or abroad x x x (italics mine)
FACTS
Hernando Conwi et al. (Conwi et al.) are employees of
Procter & Gamble Philippine Manufacturing
Corporation, a local subsidiary of U.S.-based
Procter & Gamble.
Conwi et al. were temporarily assigned to
subsidiaries of Procter & Gamble outside of the
Philippines, where they were paid in U.S. dollars.
It is claimed that they earned and spent their money
exclusively abroad, and that they did not remit
money back into the Philippines during the time they
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