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July 23, 2026
Executive Rule No. 47 outlines the tax treatment for an Incorporated Body subject to treaties for the avoidance of double taxation. It establishes controls for approving exempted revenue, requiring its inclusion with related costs in the tax declaration, supported by all necessary documents. The Rule specifies expenses disallowed against such revenues, including direct costs, and portions of agent's commission, head office expenses, indirect administrative expenses, and contract insurance. It also stipulates that special and exceptional cases must be treated separately after consulting with the Tax Department.
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