It has been reported that the Ministry of Finance, on 11 April 2007, issued a ruling clarifying the tax treatment of foreign companies on the basis of deemed profits as stipulated in Art. 25 of the Income Tax Act. The Ruling applies retroactively from 1 April 2007 and the contents are summarized below.
Under Art. 25 of the Income Tax Act, a foreign entity deriving income from technical assistance, construction, international transport and leasing of m…