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HMRC internal manual

Double Taxation Relief Manual

DT: Philippines: double taxation agreement, Article 1: Personal scope

(1) This Convention shall apply to persons who are residents of one or both of theContracting States.

(2) However, nothing in this Convention shall prevent the Philippines from taxing its owncitizens, who are not residents of the Philippines, in accordance with Philippine laws butthe United Kingdom shall not be bound to give credit for such tax.