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What is SC Johnson Tax Treaty Dispute Summary about?

The Supreme Court ruled that SC Johnson Philippines was not entitled to the 10% withholding tax rate on royalty payments to its US parent company under the Philippines-US tax treaty by invoking the most favored nation clause and the Philippines-Germany tax treaty. This is because the two tax treaties do not provide similar relief from double taxation - the Philippines-Germany treaty allows a 20% tax credit on gross royalty payments, while no such credit exists in the Philippines-US treaty. As the tax burden

Author

Ronn Robby Rosales

Language

EN