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AAC Tax Code.

The National Internal Revenue Code of 1997 as it currently stands — consolidated by the firm to carry the TRAIN Law, the CREATE Act, the Ease of Paying Taxes Act, the VAT on Digital Services Act, CREATE MORE, the CMEPA and the amendatory laws in force to 1 August 2026, with a footnote at every provision naming the law that changed it.

Text current as at 1 August 2026. This is an unofficial consolidation prepared by the firm and not the official text of the Code. Repealed provisions are kept, struck through, so that references in earlier records stay traceable.
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The printed edition runs to 240 pages and carries the same text, footnotes and references as the browser below. Every section here shows the page it sits on in that PDF, so a citation taken from the screen matches the one taken from the book.

TITLE II — TAX ON INCOME › CHAPTER III. — TAX ON INDIVIDUALS

SEC. 25. Tax on Nonresident Alien Individual

Page 17 of the PDF edition

(A) Nonresident Alien Engaged in Trade or Business Within the Philippines

(1) In General. — A nonresident alien individual engaged in trade or business in the Philippines shall be subject to income tax under Section 24 of this Code on taxable income received from all sources within the Philippines. A nonresident alien individual who shall come to the Philippines and stay therein for an aggregate period of more than one hundred eighty (180) days during any calendar year shall be deemed a ‘nonresident alien doing business in the Philippines’, Section 22(G) of this Code notwithstanding.

(2) Cash and/or Property Dividends from a Domestic Corporation or Joint Stock Company, or Insurance or Mutual Fund Company or Share in the Distributable Net Income of a Partnership (Except a General Professional Partnership), Joint Account, Joint Venture Taxable as a Corporation or Association. — Cash and/or property dividends from a domestic corporation, joint stock company, insurance or mutual fund company, or the share of a nonresident alien individual in the distributable net income after tax of a partnership (except a general professional partnership) of which he is a partner, or the share of a nonresident alien individual in the net income after tax of an association, joint account, or joint venture taxable as a corporation of which he is a member or a co-venturer shall be subject to an income tax of twenty percent (20%) on the total amount thereof.

(3) Nonresident Cinematographic Film Owner, Lessor, or Distributor. — Cinematographic films and similar works shall be subject to the tax provided under Section 28 of this Code.

(B) Nonresident Alien Individual Not Engaged in Trade or Business Within the Philippines. — There shall be levied, collected and paid for each taxable year upon the entire income received from all sources within the Philippines by every nonresident alien individual not engaged in trade or business within the Philippines, such as interest, cash and/or property dividends, rents, salaries, wages, premiums, annuities, compensation, remuneration, emoluments, or other fixed or determinable annual or periodic or casual gains, profits, and income, a final tax equal to twenty-five percent (25%) of such income. Capital gains realized by a nonresident alien individual not engaged in trade or business in the Philippines from the sale, exchange, or other disposition of shares of stock not traded in a local or foreign stock exchange and real property shall be subject to the income tax prescribed under Subsections (B)(3) and (B)(4) of Section 24.

(C) Alien Individual Employed by Regional or Area Headquarters and Regional Operating Headquarters of Multinational Companies. — There shall be levied, collected and paid for each taxable year upon the gross income received by every alien individual employed by regional or area headquarters and regional operating headquarters established in the Philippines by multinational companies as salaries, wages, annuities, compensation, remuneration and other emoluments, such as honoraria and allowances, from such regional or area headquarters and regional operating

headquarters, a tax equal to fifteen percent (15%) of such gross income: Provided, however, That the same tax treatment shall apply to Filipinos employed and occupying the same position as those of aliens employed by these multinational companies. For purposes of this Chapter, the term ‘multinational company’ means a foreign firm or entity engaged in international trade with affiliates or subsidiaries or branch offices in the Asia-Pacific Region and other foreign markets.

(D) Alien Individual Employed by Offshore Banking Units. — There shall be levied, collected and paid for each taxable year upon the gross income received by every alien individual employed by offshore banking units established in the Philippines as salaries, wages, annuities, compensation, remuneration and other emoluments, such as honoraria and allowances, from such offshore banking units, a tax equal to fifteen percent (15%) of such gross income: Provided, however, That the same tax treatment shall apply to Filipinos employed and occupying the same position as those of aliens employed by these offshore banking units.

(E) Alien Individual Employed by Petroleum Service Contractor and Subcontractor. — An alien individual who is a permanent resident of a foreign country but who is employed and assigned in the Philippines by a foreign service contractor or by a foreign service subcontractor engaged in petroleum operations in the Philippines shall be liable to a tax of fifteen percent (15%) of the salaries, wages, annuities, compensation, remuneration and other emoluments, such as honoraria and allowances, received from such contractor or subcontractor: Provided, however, That the same tax treatment shall apply to a Filipino employed and occupying the same position as an alien employed by petroleum service contractor and subcontractor.

Any income earned from all other sources within the Philippines by the alien employees referred to under Subsections (C), (D) and (E) hereof shall be subject to the pertinent income tax, as the case may be, imposed under this Code.

(F) The preferential tax treatment provided in Subsections (C), (D), and (E) of this Section shall not be applicable to regional headquarters (RHQs), regional operating headquarters (ROHQs), offshore banking units (OBUs) or petroleum service contractors and subcontractors registering with the Securities and Exchange Commission (SEC) after January 1, 2018.31

Amendment notes

  1. Subsection (G), imposing a twenty-five percent (25%) final withholding tax on the gross income of alien individuals employed by offshore gaming licensees and their service providers, subject to a minimum of Twelve thousand five hundred pesos (P12,500) for any taxable month, was introduced by sec. 3 of Republic Act No. 11590, approved 22 September 2021. Republic Act No. 11590 was repealed in its entirety by sec. 18 of Republic Act No. 12312, the Anti-POGO Act of 2025, approved 23 October 2025, which bans and criminalises offshore gaming operations. The amendments it introduced are accordingly spent. Republic Act No. 12312 contains no clause reviving the text that preceded them.
  2. Capital Markets Efficiency Promotion Act (RA 12214), sec. 5, approved 29 May 2025 — Subsections (A) and (B) amended. Before the amendment paragraph (A)(1) taxed the nonresident alien engaged in trade or business “in the same manner as an individual citizen and a resident alien individual”; paragraph (A)(2) also covered interests, royalties, prizes and other winnings, exempted interest on long-term deposits and investments and taxed pre-terminated deposits at graduated rates set out in a schedule, and referred to regional operating headquarters of multinational companies; paragraph (A)(3) dealt with capital gains and cross-referred to Sections 24(C) and 24(D); and Subsection (B) imposed the tax on gross income including capital gains and cross-referred to Sections 24(C) and 24(D). Subsections (C) to (F) were not amended and are printed “x x x” in the Act.
  3. TRAIN Law, sec. 6 — inserted.
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