This case has been cited 1 times or more.
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2016-01-11 |
LEONEN, J. |
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| In Deutsche Bank AG Manila Branch v. Commissioner of Internal Revenue,[78] this court stressed the binding effects of tax treaties. It dealt with the issue of "whether the failure to strictly comply with [Revenue Memorandum Order] RMO No. 1-2000[79] will deprive persons or corporations of the benefit of a tax treaty."[80] Upholding the tax treaty over the administrative issuance, this court reasoned thus: Our Constitution provides for adherence to the general principles of international law as part of the law of the land. The time-honored international principle of pacta sunt servanda demands the performance in good faith of treaty obligations on the part of the states that enter into the agreement. Every treaty in force is binding upon the parties, and obligations under the treaty must be performed by them in good faith. More importantly, treaties have the force and effect of law in this jurisdiction. | |||||