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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Philippines: double taxation agreement, Article 18: Governmental functions

(1) Remuneration paid out of public funds of the United Kingdom or Northern Ireland orof the funds of any local authority in the United Kingdom to any individual in respect ofservices rendered to the Government of the United Kingdom or Northern Ireland or a localauthority in the United Kingdom in the discharge of functions of a governmental nature,shall be taxable only in the United Kingdom unless the individual is a Philippine nationalwithout also being a United Kingdom national.

(2) Remuneration paid out of public funds of the Philippines or of the funds of any localauthority thereof to any individual in respect of services rendered to the Government ofthe Philippines or a local authority thereof, in the discharge of functions of agovernmental nature, shall be taxable only in the Philippines unless the individual is aUnited Kingdom national without also being a Philippine national.

(3) Pensions paid out of public funds of the United Kingdom or Northern Ireland or of thefunds of any local authority in the United Kingdom to any individual in respect ofservices rendered to the Government of the United Kingdom or Northern Ireland or a localauthority in the United Kingdom in the discharge of functions of a governmental natureshall be exempt from Philippine tax.

(4) Pensions paid out of public funds of the Philippines or of the funds of any localauthority thereof to any individual in respect of services rendered to the Government ofthe Philippines or a local authority thereof, in the discharge of functions of agovernmental nature shall be exempt from United Kingdom tax.

(5) The provisions of Articles 14, 15 and 17, as the case may be, shall apply toremuneration or pensions m respect of services rendered in connection with any trade orbusiness carried on by a Contracting State or a political subdivision or a local authoritythereof.