In addition, any profit remitted by a branch to its head office is subject to a fifteen percent tax (15%) tax. (This tax does not apply to firms registered with the Philippine Economic Zone Authority which are under a special tax regime under a special law).

The taxation of passive income of resident foreign corporations is aligned with the taxation of passive income of domestic corporations.

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Income of offshore banking units (OBUs) from foreign currency transactions with local commercial banks, and branches of foreign banks is subject to a ten percent (10%) tax on gross income. Interest income from foreign currency loans which are granted to residents are also subject to a ten percent (10%) tax on gross income. The tax does not apply to income of nonresidents from transactions with OBUs.

Income derived under the foreign currency deposit system including interest income from foreign currency loans are subject to a ten percent (10%) tax on gross income

Regional operating headquarters which are branches of multinational companies and are engaged in general administration and planning; business planning and coordination; sourcing and procurement of raw materials; corporate finance advisory services; marketing control and sales promotion; training and personnel development; logistic services; research and development services and product development; technical support and maintenance; data processing and communications; and business development, are subject to a ten percent tax (10%) tax on their taxable income (Sec. 28 (A) (6).

International carriers which are doing business with the Philippines are subject to a two and one-half percent (2 ½

%) tax on their gross Philippine billings. These refer to their gross revenues from carriage of persons, cargoes, and mail

originating from the Philippines in a continuous and uninterrupted flight.