ARTICLE 16
U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States
Dependent Personal Services
(1) Except as provided in Article 20 (Governmental Functions), wages, salaries, and similar remuneration derived by an individual who is a resident of one of the Contracting States from labor or personal services performed as an employee, including income from services performed by an officer of a corporation, may be taxed by that Contracting State. Except as provided by paragraphs (2) and (3) and in Articles 20 (Governmental Functions), 21 (Teachers), and 22 (Students and Trainees), such remuneration derived from sources within the other Contracting State may also be taxed by that other Contracting State.
(2) Remuneration described in paragraph (1) derived by an individual who is a resident of one of the Contracting States shall be exempt from tax by the other Contracting State if (a) He is present in that other Contracting State for a period or periods aggregating less than 90 days in the taxable year;
(b) He is an employee of a resident of, or of a permanent establishment maintained in, the first-mentioned Contracting State; and
(c) The remuneration is not borne as such by a permanent establishment which the employer has in that other Contracting State.
(3) Notwithstanding the preceding provisions of this article, remuneration derived by an employee of a resident of one of the Contracting States for labor or personal services performed as a member of the regular complement of a ship or aircraft operated in international traffic by a resident of that Contracting State may be taxed only by that Contracting State.
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