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Philippine Bar review · Question

Practice question: Criteria in Imposing Income Tax

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Practice question

Explain the qualifying overseas-contract-worker rule in Section23(C), including its express seaman proviso. Why is it wrong to treat it as exemption from every Philippine-source receipt?

Legal references

  • NIRC, Sections 5-7,22-23 and32, as enacted in RA8424 and subject to the cited later amendments: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html
  • RA12214, May29,2025, CMEPA, including amended NIRC Sections22,25 and32: https://lawphil.net/statutes/repacts/ra2025/ra_12214_2025.html
  • RA12066, CREATE MORE, Section3 amending NIRC32(B)(5) treaty exclusions: https://lawphil.net/statutes/repacts/ra2024/ra_12066_2024.html

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