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to his income derived from sources abroad until the date of his arrival in the
Philippines.
4. The taxpayer shall submit proof to the Commissioner of Internal Revenue to
show his intention of leaving the Philippines to reside permanently abroad or
to return to and reside in the Philippines as the case may be for purposes of
the said Section of the Tax Code.
Such being the case, and since the aforesaid employees were assigned abroad for
less than 183 days during a taxable year, they do not therefore, fall within the
purview of the above definition of non-resident citizen. Accordingly, this Office is of
the opinion as it hereby holds that the said employees are resident citizens. Hence,
their compensation income even if paid by a foreign employer through an agent in
the Philippines are subject to the tax imposed under Section 24 (A) of the Tax Code,
as amended. (BIR Ruling No. 004-95 dated January 6, 1995, and DA-266-98 dated
June 24, 1998)
This ruling is being issued on the basis of the foregoing facts as represented.
However, if upon investigation, it will be disclosed that the facts are different, then
this ruling shall be considered as null and void.
Very truly yours,