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FOREIGN
CORPORATION
NON-RESIDENT FOREIGN
CORPORATION, SECTION 28(B)
GENERAL PRINCIPLE
Note: If the domicile country of NRFC does not allow tax credit, NRFC is
subject to 30% FCIT (as amended by RA 9337)
INTERCOPERATE DIVIDENDS
1. UKCO, a foreign corporation, earned 70% of its total gross income from
its Philippine business during the years of 2009-2012. In 2013, UKCO paid
P100,000.00 dividends to UK Phil, a resident foreign Corp.