Philippines: ECQ and GCQ Guidelines; Further Extension of Deadlines for Tax Payments

This is a briefing on the following issuances as of May 3, 2020 in relation to the COVID-19 pandemic:


A. Guidelines for Areas Under Enhanced Community Quarantine (ECQ) and General Community Quarantine (GCQ)

B. Extensions of Deadlines to Pay National and Local Taxes

C. Extension of Deadlines for Filings with the Intellectual Property Office of the Philippines (IPOPHL)

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A. Guidelines for Areas Under Enhanced Community Quarantine (ECQ) and General Community Quarantine (GCQ)


1. IATF Omnibus Guidelines on the Implementation of the Community Quarantine in the Philippines

a. The President has issued Executive Order No. 112 (Imposing an Enhanced Community Quarantine in High-Risk Geographic Areas of the Philippines and a General Community Quarantine in the Rest of the Country from 01 to 15 May 2020, Adopting the Omnibus Guidelines on the Implementation Thereof, and for Other Purposes) dated April 30, 2020 (EO 112).[1] The link to the full text is https://www.officialgazette.gov.ph/downloads/2020/04apr/2020030-EO-112-RRD.pdf.

b. EO 112 provides that the enhanced community quarantine (ECQ) is extended until to May 15, 2020 over high-risk areas, namely: National Capital Region (NCR), Region III (Central Luzon) except Aurora Province, Region IV-A (CALABARZON), Benguet Province, Pangasinan Province, Iloilo Province, Cebu Province, Bacolod City, and Davao City.

c. A general community quarantine (GCQ) is imposed from May 1 to May 15, 2020 in all other areas of the Philippines, “provided that, as a precondition, minimum health standards are achieved and continuously observed in these areas.” The GCQ may be lifted by the Inter-Agency Task Force for the Management of Emerging Infectious Diseases (IATF) after May 15 if “no deterioration in their risk level occurs.”

d. A mandatory grace period of 30 days for “residential and commercial rents falling due within the duration of the ECQ and GCQ upon residential lessees and micro-, small, and medium enterprises (MSMEs) not permitted to operate during said period” from “the last due date, or until such time that the community quarantine is lifted …, whichever is longer, without incurring interests, penalties, fees, or other charges” is also imposed by EO 112.

e. EO 112 also adopts the IATF’s Resolution No. 30 on the Omnibus Guidelines on the Implementation of the Community Quarantine in the Philippines (IATF Omnibus Guidelines).

The IATF Omnibus Guidelines enumerate the industries allowed to operate in areas placed under ECQ and GCQ (as grouped in categories).

A summary of the IATF Omnibus Guidelines is set out in the table below.

The IATF Omnibus Guidelines defines “skeletal workforce” as “the operational capacity which utilizes the smallest number of people needed for a business or organization to maintain its basic function.

Offices and Businesses Allowed to Operate based on the IATF Omnibus Guidelines
Areas under ECQ	Areas under GCQ
Government Offices
All agencies and instrumentalities of the government, including GOCCs and LGUs (skeletal workforce)	Full operational capacity or alternative work arrangements in accordance with Civil Service Commission guidelines
Diplomatic Missions and International Organizations
“Officials and employees of foreign diplomatic missions and international organizations accredited by the Department of Foreign Affairs (DFA), whenever performing diplomatic functions and subject to DFA guidelines” (skeletal workforce)	50% operational capacity or alternative work arrangements (e.g., flexible work arrangements, compressed work week, telework, and telecommuting is strongly encouraged)
Essential Goods and Services
Agriculture, fishery, and forestry industries (full operational capacity) Food retail establishments (e.g., public markets, supermarkets, grocery stores, convenience stores) and food preparation establishments for take-out and delivery, water-refilling stations (skeletal workforce; maximum operation of 12 hours) Hospitals, medical, dental (dentists and attendants must have Personal Protective Equipment (PPE)), and optometry clinics (skeletal workforce) Pharmacies and drugstores (skeletal workforce; maximum operation of 12 hours) Veterinary clinics (skeletal workforce) Manufacturing and processing plants of: Basic food products (maximum of 50% of workforce, but may operate at a higher capacity if needed) Medicines, medical supplies, devices, and equipment (full operational capacity) Essential products (e.g., soap and detergents, diapers, feminine hygiene products, toilet papers and wet wipes, and disinfectants) (skeletal workforce) Delivery services, in-house or outsourced: Food, medicine, other essential goods, “clothing, accessories, hardware, housewares, school and office supplies, pet food, and other veterinary products” (skeletal workforce) “Telecommunications companies, internet service providers, cable television providers” (skeletal workforce) Media establishments (skeletal workforce)	Category I Industries (full operational capacity) Agriculture, fishery, and forestry industries Food manufacturing and food supply chain businesses, including food retail establishments (e.g., supermarkets, grocery stores (maximum operation of 12 hours)), and food preparation establishments insofar as take-out and delivery services, food delivery services Health-related establishments Logistics sector Information technology and telecommunication companies Media Note: “Specific industries under each category are reflected in a separate document issued by the [Department of Trade and Industry] (DTI).”
Mining, Energy, Other Manufacturing, and Maintenance Services
“Energy companies, their third-party contractors and service providers, including employees involved in: Electric transmission and distribution, electric power plant and line maintenance, electricity market and retail suppliers, Exploration, operations, trading and delivery of coal, oil, crude or petroleum and by-products (gasoline, diesel, liquefied petroleum gas, jet oil, kerosene, lubricants), including refineries and depots or any kind of fuel used to produce electricity” (skeletal workforce) “Power, energy, water, information technology and telecommunications supplies and facilities, including waste disposal services, as well as property management and building utility services” (skeletal workforce) “Airline and aircraft maintenance employees, including pilots and crew, ship captains and crew” (skeletal workforce)	Category II Industries (between 50% up to full operational capacity; without prejudice to alternative work arrangements) Mining Other manufacturing, export-oriented, and electronic commerce companies Other delivery, repair and maintenance, and housing and office services Note: “Specific industries under each category are reflected in a separate document issued by the DTI.”
Financial, Business Processing Outsourcing (BPOs), and Other Services
“Banks, money transfer services, microfinance institutions, excluding pawnshops not performing money transfer, and credit cooperatives, including their armored vehicle services, if any” (skeletal workforce) “Capital markets, including but not limited to the Bangko Sentral ng Pilipinas, Securities and Exchange Commission, Philippine Stock Exchange, Philippine Dealing and Exchange Corporation, Philippine Securities Settlement Corporation, and Philippine Depository and Trust Corporation” (skeletal workforce) BPOs and export-oriented business (with work-from-home, on-site or near side accommodation, or point-to-point shuttling arrangements)	Category III Industries (maximum of 50% work-on-site arrangement; without prejudice to alternative work arrangements) Financial services BPOs Legal and accounting, and auditing services Professional, scientific, technical, and other non-leisure services Barber shops, salon, and other personal care services Other non-leisure wholesale and retail establishments Note: “Specific industries under each category are reflected in a separate document issued by the DTI.”
Construction
Construction of projects accredited by the Department of Public Works and Highways (DPWH) for quarantine and isolation, flood control, and other disaster risk reduction and rehabilitation works (skeletal workforce) “Manufacturing companies and suppliers of equipment or products necessary to perform construction works” (skeletal workforce) Utility relocation works and limited works in 13 railway projects as accredited by the Department of Transportation (DOTr) (with on-site or near-site accommodations, where applicable, and/or shuttle services)	Essential public and private construction projects (e.g., sewerage, water services facilities, digital works, health facilities) and priority projects in accordance with DPWH guidelines
Public Transport
Suspended but shuttle services of employees allowed to work will be allowed to operate	Allowed to operate but at a reduced capacity in accordance with DOTr guidelines
Schools
“Physical classes at all levels shall be suspended for the duration of the ECQ.”	“Physical classes shall be suspended for the duration of the GCQ.” However, “Higher Education Institutions (HEIs) may hold classes through flexible learning arrangements to finish the Academic Year 2019-2020, and may operate at a limited capacity to receive students’ requirements and prepare and issue credentials to students” in accordance with Commission on Higher Education (CHED) guidelines
Hotels and Similar Establishments
“No hotels or similar establishments shall be allowed to operate, except those accommodating the following: For areas outside Luzon, guests who have existing booking accommodations for foreigners as of May 1, 2020 Guests who have existing long-term bookings Distressed Overseas Filipino Workers (OFWs) and stranded Filipinos or foreign nationals Repatriated OFWs in compliance with approved quarantine protocols Non-OFWs who may be required to undergo mandatory facility-based quarantine, and Health care workers and other employees from exempted establishments under these Omnibus Guidelines and applicable Memoranda from the Executive Secretary Provided that in all of the foregoing, hotel operations shall be limited to the provision of basic lodging to guests.”
Other Industries
Philippine Postal Corporation (“at a capacity necessary to maintain the prompt delivery services”) Philippine Statistics Authority (“at a capacity necessary to conduct data gathering and survey activities related to COVID-19 and the registration and implementation of the national identification (ID) system”) Funeral (with shuttle services and/or housing accommodations) and embalming services (both skeletal workforce) Humanitarian assistance (e.g., civil society organizations (CSOs), non-government organizations (NGOs), and United Nations-Humanitarian Country Teams) and individuals engaged in relief operations authorized by the government Religious personnel performing necrological services “Immediate family members of the deceased from causes other than COVID-19 shall be allowed to move from their residences to attend the wake or interment of the deceased upon satisfactory proof of their relationship with the latter and social distancing measures” Security personnel (skeletal workforce)	Non-leisure establishments and services in malls (50% operational capacity; alternative work arrangements strongly encouraged) Persons below 21 years old and 60 years old and above may only enter “when indispensable under the circumstances for obtaining essential goods and services or for work in establishments located therein”

f. The declaration of ECQ and GCQ under EO 112 supersedes any form of community quarantine imposed by local government units (LGUs). Starting May 16, 2020, the authority to “impose, lift, or extend a community quarantine” in LGUs will rest on the following:

(i) IATF for provinces, highly-urbanized cities, and independent component cities;

(ii) provincial governors, “upon the concurrence of the relevant regional counterpart body of the IATF,” for component cities and municipalities; and

(iii) mayors of cities and municipalities, “upon the concurrence of the relevant regional counterpart body of the IATD,” for barangays.

EO 112 provides that the foregoing is without prejudice to “the authority of the IATF to directly impose, lift or extend ECQ in these areas should circumstances call for it.”


2. Workplace Guidelines for Areas under ECQ and GCQ

a. The Department of Trade and Industry (DTI) and Department of Labor and Employment (DOLE) have issued Interim Guidelines (Interim Guidelines on Workplace Prevention and Control of COVID-19) dated April 30, 2020 [2] prescribing the “minimum health protocols and standards in light of the COVID-19 pandemic” to be implemented in workplaces allowed to operate during the ECQ and GCQ. These guidelines will apply to “all workplaces, employers, and workers in the private sector.”

b. The Philippine Economic Zone Authority (PEZA) has also issued Memorandum Circular No. 2020-0024 (Guidelines for Preparing the PEZA Workplace for COVID-19 Response after Lifting of the Enhanced Community Quarantine (ECQ)) dated April 22, 2020 [3] prescribing the guidelines to be followed within the PEZA workplace once the ECQ has been lifted.


3. Transportation Guidelines for Areas under GCQ

a. Even under GCQ, public transportation is limited. The DOTr has released the Guidelines for Public Transport Operations for Areas under GCQ on its Facebook page. [4] The Guidelines cover road, aviation, maritime, and railway transportation sectors.

b. The guidelines for the operation of road-based public transport for areas under GCQ provide that passengers must follow strict social distancing and minimum public health standards (e.g., wearing of face masks for passengers and gloves for drivers). Passenger load per mode of transportation must also not exceed 50% of the regular load. [5] For detailed illustrations on the implementation of social distancing in road-based public transportation, please refer to the infographics and summary of guidelines posted in the DOTr’s Facebook page. [6]

b. Private cars “will be allowed to operate for the purpose of essential travels as defined by the IATF. [C]ars will only be allowed one passenger to occupy the front passenger seat, while front-facing seats shall not exceed two passengers per row. Motorcycles are prohibited from having backride passengers.”

c. On May 3, 2020, the National Task Force (NTF) Against COVID-19 announced the temporary restriction of “flight operations at the Ninoy Aquino International Airport (NAIA) in Manila and all other international airports in the country” [7] from 8:00 AM of May 3, 2020 until May 9, 2020. [8] The restriction covers both international and domestic flights.

d. The following are excluded from the temporary restriction: (i) emergencies while en route, (ii) cargo flights, (iii) air ambulance and medical supplies flights, (iv) weather mitigation flights, (v) maintenance flights, and (vi) “sweeper flights for foreign nationals repatriating back to their respective countries.”

e. International flights intending to seek exemption are required to make a “request exemption with the [Civil Aviation Authority of the Philippines Operations Center] (CAAP OPCEN) at least 36 hours before the scheduled departure from their place of origin.”


B. Extensions of Deadlines to Pay National and Local Taxes


1. National Taxes

a. Revenue Regulations (RR) No. 11-2020 (Amends Section 2 of Revenue Regulations No. 10-2020 relative to the extension of statutory deadlines and timelines for the filing and submission of any document and the payment of taxes pursuant to Section 4(z) of Republic Act No. 11469, otherwise known as “Bayanihan to Heal As One Act”) dated April 29, 2020 has been issued by the Secretary of Finance to amend RR No. 10-2020 [9] in view of the extension of the ECQ period until May 15, 2020 over high risk areas including the NCR. The full text of RR No. 11-2020 is at [10].

The term “quarantine” in RR No. 11-2020 refers to “any announcement by the National Government resulting to limited operations and mobility, including, but not limited to, community quarantine, enhanced community quarantine, modified community quarantine, and general community quarantine.”

The RR applies to the entire Philippines even if some areas are already under GCQ.

b. RR No. 11-2020 further extends the due dates for the filing and submission of documents and payment of taxes falling within the extended period in RR 10-2020.

A summary of the extended deadlines is set out in the table below.

Type of Tax/Filing	Extended Deadline under RR No. 11-2020
Income Tax
Filing and payment of annual income tax of corporations for calendar year 2019, as provided in Section 2 (item 10) of RR No. 11-2020	June 30, 2020
Filing and payment of annual income tax for individuals for calendar year 2019, as provided in Section 2 (item 25) of RR No. 11-2020	June 14, 2020
Filing of “quarterly income tax return for corporations” for the 1st calendar quarter of 2020, as provided in Section 2 (item 46) of RR No. 11-2020	June 29, 2020
Filing and payment of “quarterly income tax return for self-employed individuals, estates, and trusts” for the 1st calendar quarter of 2020, as provided in Section 2 (item 47) of RR No. 11-2020	June 14, 2020
“Annual Capital Gains Tax Return for Onerous Transfer of Shares of Stock Not Traded Through the Local Stock Exchange” (Annual CGT Return)
Deadline for filing and payment of Annual CGT Return for calendar year 2019, as provided in Section 2 (item 44) of RR No. 11-2020	June 14, 2020
Deadline for filing and payment of Annual CGT Return for fiscal year ending January 31, 2020, as provided in Section 2 (item 44) of RR No. 11-2020	June 14, 2020
Value-added tax (VAT) Refund Applications
Deadline for VAT refund applications for the period covering the calendar quarter ending March 31, 2018, as provided in Section 2 (item 1) of RR No. 11-2020	May 30, 2020, or 30 days from the lifting of the quarantine, whichever comes later
Deadline for VAT refund applications for the period covering the fiscal quarter ending April 30, 2018	June 14, 2020, or 30 days from the date of the lifting of the quarantine, whichever comes later
Deadline for VAT refund applications for the period covering the fiscal quarter ending May 31, 2018	June 30, 2020, or 30 days from the date of the lifting of the quarantine, whichever comes later
Tax Amnesty Return on Delinquencies
Deadline of Filing Tax Amnesty Return on Delinquencies as provided in Section 2 (item 34) of RR No. 11-2020	June 22, 2020
The deadlines for the following filings and submissions (including those falling within the extension period) remained to be reckoned from the lifting of the quarantine
“One-time transactions” as provided in Section 2 (item 2) of RR No. 11-2020	30 days from the date of the lifting of the quarantine
Position papers, protests, additional documents and other documents as provided in Section 2 (item 31) of RR No. 11-2020	30 days from the date of the lifting of the quarantine
“Suspension of running of limitations under Sections 203 and 222 pursuant to Section 223 of the Tax Code of 1997, as amended” as provided in Section 2 (item 32) of RR No. 11-2020	60 days after the lifting of the quarantine
Deadline for submission of “Certificate of Residence for Tax Treaty Relief” [11] for final withholding taxes on dividends, interests, and royalties paid in March, April, and May 2020, as provided in Section 2 (item 33) of RR No. 11-2020	30 days from the date of the lifting of the quarantine
“All other filings/submissions” as provided in Section 2 (item 40) of RR No. 11-2020	30 days from the date of the lifting of the quarantine

c. RR No. 11-2020 also extends the deadlines for the filing and payment various withholding, percentage and excise taxes as provided in Section 2 (items 41 to 50) of RR No. 11-2020.

d. RR No. 11-2020 expressly provides that “if the new extended due dates fall on a holiday or non-working day, then, the submission and/or filing contemplated herein shall be made on the next working day.” However, in news releases, the Commissioner of Internal Revenue has stated that “since the newest June 14 deadline fell on a Sunday while the Friday before that, June 12, is a holiday (Independence Day), the actual cut-off date will be on June 11, a Thursday.” [12]

“In case of another quarantine extension,” the extended due dates in RR No. 11-2020 “shall be further extended for 15 calendar days” from the extended due dates in RR No. 11-2020.

e. RR No. 11-2020 reiterates the guidelines in RR No. 10-2020 for tax returns filed on or before the extended deadlines.


2. Local Taxes

a. The DOF has issued Department Circular No. 002-2020 dated April 23, 2020 [13] and it allows taxpayers until June 25, 2020 to pay “taxes, fees, and charges of local government units (LGUs)” which are due as of March 25, 2020.

This circular is issued pursuant to Section 4(z) of R.A. No. 11469 or the Bayanihan to Heal As One Act (Bayanihan Act). It is effective “immediately upon publication in a newspaper of general circulation” and will remain effective “until the state of public health emergency is lifted, subject to changes issued or instructed by the Office of the President.”

b. The circular provides the following:

(i) The deadlines for the payment “of all local taxes, fees and charges duly authorized and imposed by LGUs within their respective territorial jurisdictions as of March 25, 2020” is extended to June 25, 2020. In addition, “the counting of the period within which to pay local taxes, fees, and charges shall likewise be suspended during the said period.”

(ii) If a LGU has previously extended the deadlines prior to the effectivity of the Bayanihan Act on March 26, 2020, such deadlines “shall be deemed modified with the period set [in the circular].” Any further extensions “shall be authorized in accordance with the provisions of the Local Government Code.”

(iii) As a result of the extension, “no interest, surcharge or any form of penalty shall be applied on any local tax, fee or charge accruing on or due and demandable” during the extension period.”

The DOF has clarified that “all previous delinquencies shall be due and the accrual of interest, penalties and surcharges shall begin after the extension.”

(iv) Local treasurers and assessors are instructed to defer the following:

- “issuing written authority for the conduct of examination of books of accounts and pertinent business records;”

- “activities related to appraisal and assessment of real properties,”

- “posting and publishing of notices of delinquencies, warrants of levy, and advertisements for sale or auction,” and

-“pursuing administrative or judicial action for the enforcement and/or collection of local taxes, fees, or charges.”


For more information about tax issuances, please contact your account partner or the author of this client bulletin:

Carina C. Laforteza
Partner; Head of the Tax Department
cclaforteza@syciplaw.com


C. Extension of Deadlines for Filings with the Intellectual Property Office of the Philippines (IPOPHL)

a. The IPOPHL has issued IPOPHL Memorandum Circular No. 2020-011 (Updated Advisory on IPOPHL Services in Light of the Extension of the Enhanced Community Quarantine to 15 May 2020) dated April 27, 2020. [14]

b. The advisory provides the following extensions for filing of papers, pleadings, documents, and payments falling due from March 16, 2020 to May 15, 2020 for:

(i) For deadlines falling from March 16, 2020 to March 31, 2020, submissions may be filed until May 31, 2020.

(ii) For deadlines falling from April 1, 2020 to May 15, 2020, filing is extended for a period of sixty (60) calendar days from the due date.

c. The extension set out in (b) above does not cover the following:

(i) “Filings and proceedings in relation to the voluntary surrender of patents, utility models, and industrial designs… To facilitate the processing, formal requirement on verification shall be complied with upon resumption of normal operations.”

(ii) “For invention, utility model, industrial design and trademark applications claiming priority date, online filing must be used to comply with the prescribed period for claiming of priority date.”

d. There is a 60-day period extension of the “[p]ayment of filing fees including claim for convention priority fees of new applications for patents, utility models, industrial designs, and trademarks, with or without the claim of priority date, which are filed through the IPOPHL electronic filing systems,” and the extended period will be counted from the due date. “If the 60th day falls on a weekend or holiday, payment shall be on the next working day. The date when the application was filed online shall be deemed the filing date. However, applicants may still pay using the online payment system upon filing.”

e. The Advisory also provides that “[a]ll scheduled hearings before the IPOPHL, including mediation, shall remain suspended until [May 15, 2020].”

f. The IPOPHL reminds the public that “[n]ew applications for patents, utility models, industrial designs, and trademarks from [March 16, 2020] to [May 15, 2020] may be filed online through the IPOPHL electronic filing system but processing shall commence upon resumption of work. No manual filing shall be accepted during the said period.”

g. IPOPHL personnel will continue to work-from-home arrangement until [May 15, 2020]. The IPOPHL also advises that “[t]he operations of the documentary receiving sections of IPOPHL are suspended. Letters, queries, or any other written communications may be filed on the next working day after the effectivity of the enhanced community quarantine.”


For more information about IPOPHL issuances, please contact your account partner or the author of this client bulletin:

Vida M. Panganiban-Alindogan
Partner; Head of the Intellectual Property Department
vmpanganiban@syciplaw.com


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[1] Executive Order No. 112 dated April 30, 2020; https://www.officialgazette.gov.ph/downloads/2020/04apr/2020030-EO-112-RRD.pdf; last visited at 4:24 PM on May 2, 2020.

[2] DTI and DOLE Interim Guidelines on Workplace Prevention and Control of COVID-19 dated April 30, 2020; https://dtiwebfiles.s3-ap-southeast-1.amazonaws.com/COVID19Resources/Issuances+from+other+agencies/010520_DTI_DOLE_Guidelines_Workplace_Prevention_Control_COVID19.pdf; last visited at 3:16 PM on May 2, 2020.

[3] PEZA Memorandum Circular No. 2020-0024 dated April 22, 2020; http://www.peza.gov.ph/documents/mc2020024.pdf; last visited at 4:58 PM on April 27, 2020.

[4] Omnibus Public Transport Protocols/Guidelines; https://www.facebook.com/DOTrPH/posts/1687550571384072; last visited at 5:26 PM on May 3, 2020.

[5] DOTr issues guidelines for road transport sector in areas under GCQ, DOTr Press Release dated April 30, 2020; http://dotr.gov.ph/55-dotrnews/1315-dotr-issues-guidelines-for-road-transport-sector-in-areas-under-gcq.html; last visited at 3:48 PM on May 1, 2020.

[6] DOTr Infographics for Social Distancing in road-based public transportation dated May 2, 2020; https://www.facebook.com/DOTrPH/posts/1685869848218811; last visited at 3:31 PM on May 2, 2020.

Summary of DOTr’s road-based transportation guidelines on areas under the GCQ; https://web.facebook.com/DOTrPH/posts/1685559388249857; last visited at 4:04 PM on May 1, 2020.

[7] NTF Press Release dated May 3, 2020; http://dotr.gov.ph/55-dotrnews/1341-from-the-office-of-the-national-task-force-chief-implementer-secretary-carlito-galvez-jr.html; last visited at 4:55 PM on May 3, 2020.

[8] DOTr Press Statement dated May 3, 2020; http://dotr.gov.ph/55-dotrnews/1342-on-the-decision-of-the-national-task-force-against-covid-19-for-the-temporary-suspension-of-usage-of-all-ph-international-airports-for-inbound-international-passenger-flights.html; last visited at 4:58 PM on May 3, 2020.

[9] For more information about RR No. 10-2020, see our bulletin dated April 19, 2020 at https://mailchi.mp/1f4bc482708d/further-extension-to-pay-taxes-other-covid-19-related-issuances?e=18de4b15d2.

[10] BIR RR No. 11-2020 dated April 29, 2020; https://www.bir.gov.ph/images/bir_files/internal_communications_1/Full%20Text%20RR%202020/Revenue%20Regulations%20No%2011-2020.pdf; last visited at 1:30 pm on May 2, 2020.

[11] This is the Certificate of Residency for Tax Treaty Relief purposes that is provided under Revenue Memorandum Order No. 8-2017 (Procedure for Claiming Tax Treaty Benefits for Dividend, Interest and Royalty Income of Nonresident Income Earners).

[12] BIR further extends 2019 ITR-filing, payment deadline to June 14, Philippine Daily Inquirer; https://business.inquirer.net/296303/bir-further-extends-2019-itr-filing-payment-deadline-to-june-14; last visited at 5:22 pm on May 3, 2020.

[13] DOF Department Circular No. 002-2020 dated April 23, 2020; https://drive.google.com/file/d/1oyxeKEGqetoTQdRDzYiuECUFeywGYhdb/view?fbclid=IwAR3M6QbjvGVq_9iNLEwl3MOiCAEBQGKwy9dxYi_rYxJHmmBGNrdH11SNjpM; last visited at 5:34 pm on May 3, 2020.

DOF extends deadlines for payment of local taxes, fees to June 25, waives penalties, surcharges during extended quarantine; https://www.dof.gov.ph/dof-extends-deadlines-for-payment-of-local-taxes-fees-to-june-25-waives-penalties-surcharges-during-extended-quarantine/; last visited at 2:30 pm on May 2, 2020.

[14] IPOPHL Memorandum Circular No. 2020-011 dated April 27, 2020; https://drive.google.com/file/d/1zE4qJtFVK8DwNibMHW-ceT4LK5m2TXtt/view; last visited at 2:15 PM on May 1, 2020.