Professional Documents
Culture Documents
ARTICLE 1
"ARTICLE 26
Exchange of Information
ARTICLE 2
1. Each of the Contracting States shall notify to the other the completion
of the procedures required as far as it is concerned for the bringing into force of
this Protocol. The Protocol shall enter into force on the first day of the month
following the date of receipt of the later of these notifications.
2. The provisions of this Protocol shall have effect to any calendar year
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or accounting period beginning on or after the first day of January of the calendar
year next following the date of signature of this Protocol.
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ARTICLE 1
"3. The existing taxes to which the Convention shall apply are in
particular: EIcSTD
ARTICLE 2
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However in the case of the Philippines, where there is a
conflict between the meaning of a term under the Constitution, and
its meaning under the taxation law and other laws relating to the
taxes which are the subject of the Convention, the former shall
prevail."
ARTICLE 3
ARTICLE 4
ARTICLE 5
ARTICLE 6
ARTICLE 7
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In Article 13 of the Convention, paragraph 4 is deleted.
ARTICLE 8
(i) the amount of the credit in respect to the tax paid or accrued
to France shall not exceed the same proportion of the taxes
covered by the Convention against which such credit is taken,
which the taxpayer's taxable income from sources within
France bears to his entire taxable income for the same taxable
year; and DHTECc
(ii) the total amount of the credit shall not exceed the same
proportion of the taxes covered by the Convention against
such credit is taken, which the taxpayer's taxable income from
sources without the Philippines bears to his entire taxable
income for the same taxable year.
ARTICLE 9
ARTICLE 10
ARTICLE 11
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Entry into Force
1. Each of the Contracting States shall notify to the other the completion
of the procedure required by its law for the bringing into force of this Protocol.
This Protocol shall enter into force on the date of the later of those notifications.
DONE at Paris, this 26th day of June 1995, in duplicate, in the French and
English languages, both texts being equally authentic. DISHEA
(2)
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January 9, 1976
ARTICLE 1
Personal Scope
This Convention shall apply to persons who are residents of one or both of
the Contracting States. cdasia
ARTICLE 2
Taxes Covered
ARTICLE 3
General Definitions
ARTICLE 4
Fiscal Domicile
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Contracting State of which he is a national;
ARTICLE 5
Permanent Establishment
(b) a branch;
(c) an office;
(d) a factory;
(f) a workshop;
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period.
(a) the use of facilities solely for the purpose of storage, display or
delivery of goods or merchandise belonging to the enterprise;
ARTICLE 6
ARTICLE 7
Business Profits
(i) royalties, fees or other similar payments in return for the use of
patents or other rights;
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enterprise.
7. Where profits include items of income which are dealt with separately
in other Articles of this Convention, then the provisions of those Articles shall not
be affected by the provisions of this Article.
ARTICLE 8
(a) one and one-half per cent of the gross revenues derived from
sources in the first-mentioned State; and
ARTICLE 9
Associated Enterprise
Where
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b) the same persons participate directly or indirectly in the
management, control or capital of an enterprise of a Contracting
State and an enterprise of the other Contracting State,
and in either case conditions are made or imposed between the two enterprises in
their commercial or financial relations which differ from those which would be
made between independent enterprises, then any profits which would, but for those
conditions, have accrued to one of the enterprises, but, by reason of those
conditions, have not so accrued, may be included in the profits of that enterprise
and taxed accordingly. aisa dc
ARTICLE 10
Dividends
This paragraph shall not affect the taxation of the company in respect of the
profits out of which the dividends are paid.
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through a permanent establishment situated therein, or performs in that other State
professional services from a fixed base situated therein and the holding in respect
of which the dividends are paid is effectively connected with such permanent
establishment or fixed base. In such a case the provisions of Article 7 or Article
14, as the case may be, shall apply.
ARTICLE 11
Interest
4. The term "interest" as used in this Article means income from debt
claims of every kind, whether or not secured by mortgage, and whether or not
carrying a right to participate in the debtor's profits, and in particular, income from
government securities and income from bonds or debentures, including premiums
and prizes attaching to bonds or debentures. Penalty charges for late payment shall
not be regarded as interest for the purpose of this Article.
ARTICLE 12
Royalties
ARTICLE 13
Capital Gains
3. Gains from the alienation of any property other than those mentioned
in paragraphs 1 and 2, shall be taxable only in the Contracting State of which the
alienator is a resident.
ARTICLE 14
(b) his stay in the other Contracting State is for a period or periods
amounting to or exceeding in the aggregate one hundred twenty
(120) days in the calendar year.
ARTICLE 15
1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and
other similar remuneration derived by a resident of a Contracting State in respect
of an employment shall be taxable only in that State unless the employment is
exercised in the other Contracting State. If the employment is so exercised, such
remuneration as is derived therefrom may be taxed in that other State.
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b) the remuneration is paid by, or on behalf of, an employer who
is not a resident of the other State, and
ARTICLE 16
Directors' Fees
ARTICLE 17
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State is supported substantially from the public funds of that other Contracting
State, one of its political subdivisions or local authorities or of a statutory body or
a non-profit organization thereof.
ARTICLE 18
Pensions
ARTICLE 19
Government Service
2. Any pension paid by, or out of funds created by, a Contracting State or
one of its political subdivisions or local authorities or by a statutory body thereof
to any individual in respect of services rendered to that State or subdivision or
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local authority or statutory body shall be taxable only in that State.
ARTICLE 20
Students
ARTICLE 21
2. This article shall not apply to income from research if such research is
undertaken not in the general interest but primarily for the private benefit of a
specific person or persons.
ARTICLE 22
Other Income
ARTICLE 23
(b) Income referred to in Articles 10, 11, 12, 14, 16, 17 and 22
received from the Philippines may be taxed in France. The
Philippine tax levied on such income entitles residents of
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France to a tax credit corresponding to the amount of Philippine
tax levied but which shall not exceed the amount of French tax
levied on such income. Such credit shall be allowed against
taxes referred to in sub-paragraph (a) of paragraph 3 of Article
2, in the bases of which such income is included.
but shall not exceed the amount of French tax levied on such
income.
ARTICLE 24
Non-Discrimination
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responsibilities which it grants to its own residents.
6. In this Article, the term "taxation" means the taxes to which the
Convention applies.
ARTICLE 25
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resolve by mutual agreement any difficulties arising as to the application of the
Convention. In particular, the competent authorities of the Contracting States may
consult together to endeavour to agree:
ARTICLE 26
Exchange of Information
ARTICLE 27
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income.
ARTICLE 28
Territorial Scope
ARTICLE 29
1. Each Contracting State shall notify to the other the completion of the
procedure required by its law for the bringing into force of this Convention. This
Convention shall enter into force on the date of the later of these notifications.
ARTICLE 30
Termination
2. In such an event, its provision shall have effect for the last time:
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PROTOCOL
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Endnotes
1 (Popup - Popup)
Senate Resolution No. 139-13
2 (Popup - Popup)
Protocol
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