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ARTICLE 9

U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States

Shipping and Air Transport

(1) Notwithstanding any other provision of this Convention, profits derived by a resident of one of the Contracting States from sources within the other Contracting State from the operation of ships in international traffic may be taxed by both Contracting States; however, the tax imposed by the other Contracting State may be as much as, but shall not exceed, the lesser of

(a) One and one-half percent of the gross revenues derived from sources in that State; and

(b) The lowest rate of Philippine tax that may be imposed on profits of the same kind derived under similar circumstances by a resident of a third State.

(2) Nothing in the Convention shall affect the right of a Contracting State to tax, in accordance with domestic laws, profits derived by a resident of the other Contracting State from sources within the first-mentioned Contracting State from the operation of aircraft in international traffic.

(3) The provisions of paragraphs (1) and (2) shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency.

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▸Contents — U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976
U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976

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