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Marubeni Corp. Tax Refund Case Summary by Jopan SJ is a document available to read on EtoBox.

1) Marubeni Corporation, a Japanese company with a Philippine branch, sought refund of P229,424.40 in branch profit remittance tax withheld from dividends paid to it by AG&P, a Philippine company it invested in. 2) The Commissioner of Internal Revenue denied the refund claim, reasoning that while the dividends were not branch profits, they were still subject to 25% tax under a Philippines-Japan tax treaty, and the withheld taxes of 10% and 15% equaled 25%. 3) The Court of Tax Appeals affirmed, finding the

Author

Jopan SJ

Language

EN