Practice question
Satellite airtime charges arise only upon successful transmission to Philippine gateway facilities; call setup and incomplete or unanswered calls are not billed. The material facts match Aces Philippines. The payor says the satellite being in outer space alone makes the fees wholly foreign-source. What did the MAIN decision emphasize?
- The income-producing service was completed through the Philippine gateway receipt, supporting Philippine source on those facts
- The satellite location alone conclusively settled source abroad
- Every foreign-owned computer produces foreign-source income regardless of activity
- The Court used only the bank account location
- Every cross-border service must have identical treatment without examining its income-producing event
Legal references
- Aces Philippines v. CIR, GR226680, August30 2022 ENBANC MAIN: https://lawphil.net/judjuris/juri2022/aug2022/gr_226680_2022.html MAIN activity-producing-income and situs analysis.
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