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ISRAEL AND PHILIPPINES TAX TREATY

The Convention between the Government of the Republic of the Philippines and the

Government of the State of Israel for the Avoidance of Double Taxation and the

Prevention of Fiscal evasion with respect on income.

ARTICLE 1, provides for the scope of the treaty. It provided that such convention shall

apply to persons who are residents of one or both of the Contracting State. It further

added that the Conventions shall be construed as preventing a Contracting State from

taxing its citizens who may be resideing in the other Contracting State.

ARTICLE 2, (taxes covered) It discussed the application of the convention on income

imposed on behalf of each Contracting State, irrespective of the manner in which they

are levied.

ARTICLE 4: RESIDENT

resident of the Contracting state means any person who, under the laws of that

State, is liable to tax therein by reason of his domicile, residence, place of management

or any other criterion of a similar nature.

ARTICLE 14: INDEPENDENT PERSONAL SERVICES

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Income derived by a resident of a Contracting State in respect of professional

services or other activities of an independent character shall be taxable only in that

State. However, such income may be taxed in the other Contracting state:

(a) If he has a fixed base regularly available to him in the other Contracting State

for the purpose of performing his activities but only so much of the income as

in attributable to that fixed base; or

(b) If his stay in that other State is for a period or periods aggregating six months

or more in the calendar year.

The term professional services includes specially independent scientific,

literary, artistic, educational or teaching activities, as well as the independent

activities of physicians, lawyers, engineers, architects, dentist and accountants.

ARTICLE 15: INDEPENDENT PERSONAL SERVICES

Salaries, wages and other similar remuneration derived by a resident of a

Contracting State in respect of an employment shall be taxable only in that State

unless the employment is so exercised, such remuneration as is derived there

from may be taxed in that other State.

Notwithstanding the provisions of paragraph 1, remuneration derived by a

resident of a Contracting State in respect of an employment exercised in the

other Contracting State shall be taxable only in the first-mentioned State if:

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(a) The recipient is present in the other State for a period/s not exceeding

in the aggregate 183 days in the calendar year concerned, and

(b) The remuneration is paid by, or on behalf of an employer who is not a

resident of the other State, and

(c) The remuneration is not borne by a permanent establishment or a fixed

base which the er has in the other State.

Notwithstanding the preceding provisions of this Article, remuneration derived in

respect of an employment exercised aboard a ship or aircraft operated in

international traffic by an enterprise of a Contracting State shall be taxable only in

that State.

ARTICLE 17: ARTISTS AND ENTERTAINERS

Notwithstanding the provisions of Art. 14 and 15, income derived by a

resident of a Contracting State as an entertainer such as theatre, motion picture,

radio or television artists or a musician or as an athlete from his personal

activities as such exercised in the other Contracting State may be taxed in that

other State.

Where income in respect of personal activities exercised by an entertainer

or an athlete in his capacity as such accrues not to that entertainer or athlete

himself but to anther person, that income may, notwithstanding the provisions of

Art. 7, 14, , and 16 be taxed in the Contracting State in which the activities of the

entertainer or athlete are exercised.

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ARTICLE 20: PROFESSORS AND TEACHERS

A professor of a teacher, who is a resident of a Contracting State and who visits

the other Contracting State for a period not exceeding two years for the purpose of

teaching or carrying out advanced study or research at a university, received for those

activities shall be taxable only in the first-mentioned State.

ARTICLE 22: OTHER INCOME

Items of income of a resident of a Contracting State which are not expressly

mentioned in the foregoing Articles of this Convention may be taxed in the State where

the income arises.