This, in turn, has strengthened markets and contributed to much more stable economies. This is due, in no small part, to the fact that the flow of wealth is no longer limited to local sources but has expanded through various international channels.
Seamless as the wealth moves from one state to another, our tax laws should also progress to bridge and address the gap between the wisdom brought by traditional rules of taxation and these modern transactions currently existing between nations. These rules should be as comprehensive to cover those complex transactions presented by this ever-changing world.
The source of income is determined by the location of the business activity rather than the disbursement or receipt of funds. However, RMC 38-2024 clarified that in the Supreme Court decision cited, finding the source of income of service agreement to be within the Philippines and thus subject to final withholding tax, does not automatically apply to the list provided in RMC 5-2024 of international service provision or cross-border services.
This article is for general information purposes only and should not be considered as professional advice to a specific issue or entity. The views and opinions expressed herein are those of the author and do not necessarily represent KPMG International or KPMG in the Philippines.
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