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Philippine Bar review · Question

Practice question: Situs of Income Taxation

Multiple Choice Hard

Practice question

A manufacturer produces goods in the Philippines and sells them abroad. This is not a mere purchase-and-resale transaction and no special exception applies. The manufacturer says Section42(E) makes the gain wholly foreign-source simply because the sale occurs abroad. Which is correct?
  1. Production within and sale without the Philippines produces income partly within and partly without under the stated rule
  2. Every sale abroad makes all manufacturing income foreign-source
  3. Every foreign customer makes every component Philippine-source
  4. The purchase-and-resale rule automatically erases the production rule
  5. Source is determined solely by a shipping label

Legal references

  • NIRC RA8424, relevant provisions as amended: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section42(A)(2),(4),(C)(4),(E).
  • RA12214 CMEPA: https://lawphil.net/statutes/repacts/ra2025/ra_12214_2025.html Section12, current Section42(A)(1) amendment checked.
  • Aces Philippines v. CIR, GR226680, August30 2022 ENBANC MAIN: https://lawphil.net/judjuris/juri2022/aug2022/gr_226680_2022.html MAIN income-producing activity and Philippine gateway receipt.

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