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MTF Updates -Revenue Memorandum Circular No. 20-2022 (Guidance on the Filling of Requests for Confirmation, Tax Treaty Relief Applications, and Tax Sparing Applications)

Dear Valued Clients and Friends,

We are sending you a copy of Revenue Memorandum Circular (RMC) No. 20-2022 issued by the Bureau of Internal Revenue (BIR) on February 17, 2022, providing guidance on the filing of requests for confirmation (RFC), tax treaty relief applications (TTRA) and tax sparing applications.

Under RMC No. 20-2022, taxpayers who were already issued with certificates of entitlement (for approved RFCs, TTRAs, and reduced dividend rate for tax sparing application which allows the ruling or entitlement to be applied for subsequent or future income payments need not file an RFC or TTRA every time an income of similar nature is paid to the same nonresident. Moreover, for subsequent payments to the same nonresident, the withholding agent shall be guided by the requisites set forth in the certificate of entitlement. A new RFC, TTRA, or tax sparing application shall be filed only if any of the requirements in the previously issued certificate of entitlement is no longer complied with.

The requirements and procedures laid down in Revenue Memorandum Order (RMO) No. 14-2021, as amended by RMC No. 77-2021 shall still be observed for business profits, income from services, capital gains income, and such other income from non-recurring transactions.

To recall, the BIR previously issued RMO No. 14-2021, streamlining the procedures and documentary requirements for the availment of treaty benefits, and RMC No. 77-2021, clarifying certain provisions of RMO No. 14-2021.

Should you have questions on the above article, please do not hesitate to let us know or email us at

Thank you,

Mata-Perez, Tamayo & Francisco

February 23, 2022

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