The governments of the Philippines and Ireland recently held the first round of negotiations on a proposed bilateral agreement that aims to avoid double taxation on individuals and companies in both countries.

Finance Undersecretary Antonette Tionko said the first round of talks held recently in Manila covered discussions on avoiding double taxation on income and capital gains as well as the prevention of tax evasion and avoidance.

The Philippine delegation to the talks held at the Ayuntamiento de Manila in Intramuros was led by Tionko, who heads the Revenue Operations Group (ROG) of the Department of Finance (DOF).

“While there are other provisions that need to be considered by the Philippines like Permanent Establishment and Entitlement to Benefits, the provisions on Persons Covered, the taxes to be covered, provisions on Residents and Immovable Property, and Business Profits, among others, have already been mutually agreed upon,” Tionko said.

She said a working draft of a double taxation agreement between the Philippines and Ireland is now being studied by both sides.

Also forming part of the Philippine delegation were Assistant Secretary Dakila Elteen Napao of the DOF-ROG, Deputy Commissioner Marissa Cabreros of the Legal Group of the Bureau of Internal Revenue (BIR), and OIC-ACIR Larry Barcelo of the BIR Legal Service.

Anne Margaret Gormley, Director for the Tax Treaties Branch, Office of the Revenue Commissioners of Ireland, led the Irish delegation.

“The negotiation was conducted in a friendly atmosphere with mutual understanding, which allowed the two delegations to examine all of the Articles under discussion,” Tionko said.

According to Tionko, both delegations are set to meet again to further deliberate on items that have not yet been agreed upon during the initial round of talks.

“Further, both delegations undertook to review outstanding items with their respective authorities. Once completed, arrangements will be made regarding the second round of negotiation to take place at a mutually agreed place and date,” Tionko said.

The Philippines currently has existing double taxation treaties (DTAs) with several countries, including the United States, Switzerland, the United Kingdom and Northern Ireland, United Arab Emirates, Thailand, Australia and Germany.

With a DTA in place, individuals that are residents of one country but receiving income in another contracting state or vice versa avoid being taxed twice for the same income, property or investment.

Such DTA also prevents tax evasion and encourages foreign trade and investments between countries.

Tax relief to avoid double taxation may come in the form of exemptions or preferential tax rates.

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