BL&B advises MNC’s on tax-efficient structuring of cross-border investments, including optimum use of tax treaties, choosing a business vehicle, and tax-efficient profit repatriation strategies. B&B is routinely called upon to provide advice to multinational companies with established international operations on the Philippine tax aspects of restructuring existing foreign operations.


BL&B also advises on withholding tax issues confronting foreign corporations investing in the Philippines or a Philippine company making income payments to foreign persons. Where Philippine withholding tax rules interact with tax treaty provisions, BL&B advises clients on substantive treaty issues and assists in securing treaty benefits by filing tax treaty relief applications on behalf of clients with the International Tax Affairs Division of the BIR.



  • Obtained a number of precedent-setting rulings from the BIR involving the interpretation of tax treaty provisions such as the permanent establishment, capital gains exemption, royalties, dividends and interest clauses.
  • Successfully litigated a case involving the interpretation and application of the “most-favored nation” clause of the RP-US Tax Treaty in regard to royalties, with many similarly situated US corporations later invoking the said decision in support of their refund/tax credit claims.
  • Advised a number of clients on transfer pricing issues and prepared transfer pricing reports.
  • Restructured the investment vehicle of some multinationals for maximum tax efficiency.
  • Established regional headquarters, regional operating headquarters and representative offices for multinational companies whenever more appropriate as a legal structure for business presence in the Philippines.



8/F Jollibee Centre, San Miguel Avenue 1605 Pasig City, Philippines
(632) 633-9418
(632) 633-1911; (632) 687-7674

Baniqued Layug & Bello


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