Junior Philippine Institute of Accountants

Nepal – South Korea Tax Treaty

JPIA (Junior Philippine Institute of Accountants) — Tue, 29 Nov 2011 02:45:28 +0000

Agreement between the Republic of Korea and the Kingdom of the Nepal for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
Signed at Seoul October 5, 2001
Entered into force May 29, 2003
The Government of the Republic of Korea and His Majesty’s government of Nepal, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion
with respect to taxes on income,
Have agreed as follows:
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Article 1.【PERSONS COVERED】[2003.05.29]
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
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Article 2.【TAXES COVERED】[2003.05.29]
1. The existing taxes to which this Agreement shall apply are:
a) in Korea:
(ⅰ) the income tax;
(ⅱ) the corporation tax;
(ⅲ) the inhabitant tax, and
(ⅳ) the special tax for rural development
(hereinafter referred to as “Korean tax”);
b) in Nepal:
(ⅰ) income tax imposed under the Income Tax Act, and
(ⅱ) any other taxes on income imposed by local bodies
(hereinafter referred to as “Nepal Tax”).
2. The Agreement shall apply also to any identical or substantially similar taxes which are imposed
after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The
competent authorities of the Contracting States shall notify each other of any substantial changes
which have been made in their respective taxation laws.
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Article 3.【GENERAL DEFINITIONS】[2003.05.29]
1. For the purposes of this Agreement, unless the context otherwise requires:
a) the term “Korea” means the Republic of Korea, and when used in a geographical sense,
means the territory of the Republic of Korea, including its territorial sea, and any other area
adjacent to the territorial sea of the Republic of Korea which, in accordance with international law,
has been or may hereafter be designated under the laws of the Republic of Korea as an area
within which the sovereign rights or jurisdiction of the Republic of Korea with respect to the
waters, the sea-bed and subsoil, and their natural resources may be exercised;
b) the term “Nepal” means the Kingdom of Nepal;
c) the terms “a Contracting State” and “the other Contracting State” mean Korea or Nepal, as
the context requires;
d) the term “tax” means Korean tax or Nepal tax, as the context requires;
e) the term “person” includes an individual, a company and any other body of persons;
f) the term “company” means anybody corporate or any entity which is treated as a body
corporate for tax purposes;
g) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State”
mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise
carried on by a resident of the other Contracting State;
h) the term “national” means:
(ⅰ) any individual possessing the nationality of a Contracting State;
(ⅱ) any legal person, partnership and association deriving its status as such from the laws
in force in a Contracting State;
i) the term “international traffic” means any transport by a ship or aircraft operated by an
enterprise of a Contracting State, except when the ship or aircraft is operated solely between
places in the other Contracting State;
j) the term “competent authority” means:
(ⅰ) in Korea, the Minister of Finance and Economy or his authorized representative;
(ⅱ) in Nepal, the Minister of Finance or his authorized representative.
2. As regards the application of the Agreement at any time by a Contracting State, any term not
defined therein shall, unless the context otherwise requires, have the meaning which it has at that
time under the law of that State for the purpose of the taxes to which the Agreement applies, any
meaning under the applicable tax laws of that State prevailing over a meaning given to the term
under other laws of that State.
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Article 4.【RESIDENT】[2003.05.29]
1. For the purposes of this Agreement, the term “resident of a Contracting State” means any
person who, under the laws of that State, is liable to tax therein by reason of his domicile,
residence, place of head or main office, place of management, or any other criterion of a similar
nature and also includes that State and any political subdivision or local authority thereof. This
term, however, does not include any person who is liable to tax in that State in respect only of
income from sources in that State.
2. Where by reason of the provisions of paragraph 1, an individual is a resident of both
Contracting States, then his status shall be determined as follows:
a) he shall be deemed to be a resident only of the State in which he has a permanent home
available to him; if he has a permanent home available to him in both States, he shall be deemed
to be a resident only of the State with which his personal and economic relations are closer
(center of vital interests);
b) if the State in which he has his center of vital interests cannot be determined, or if he has
not a permanent home available to him in either State, he shall be deemed to be a resident only of
the State in which he has an habitual abode;
c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a
resident only of the State of which he is a national;
d) if he is a national of both States or of neither of them, the competent authorities of the
Contracting States shall settle the question by mutual agreement.
3. Where by reason of the provisions of paragraph 1, a person other than an individual is a
resident of both Contracting States, then it shall be deemed to be a resident only of the State in
which its place of effective management is situated. In case of doubts the competent authorities of
the Contracting States shall settle the question by mutual agreement.
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Article 5.【PERMANENT ESTABLISHMENT】[2003.05.29]
1. For the purposes of this Agreement, the term “permanent establishment” means a fixed place of
business through which the business of an enterprise is wholly or partly carried on.
2. The term “permanent establishment” includes especially:
a) a place of management;
b) a branch;
c) an office;
d) a factory;
e) a workshop, and
f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.
3. A building site or a construction, assembly or installation project, or supervisory or consultancy
activities in connection therewith constitute a permanent establishment only if such site, project or
activities continue for a period or periods aggregating more than 183 days within any twelve moth
period.
4. Notwithstanding the preceding provisions of this Article, the term “permanent establishment”
shall be deemed not to include:
a) the use of facilities solely for the purpose of storage, display or delivery of goods or
merchandise belonging to the enterprise;
b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for
the purpose of storage, display or delivery;
c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for
the purposes of processing by another enterprise;
d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or
merchandise or of collecting information, for the enterprise;
e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the
enterprise, any other activity of a preparatory or auxiliary character;
f) the maintenance of a fixed place of business solely for any combination of activities
mentioned in sub-paragraphs a) to e), provided that the overall activity of the fixed place of
business resulting from this combination is of a preparatory or auxiliary character.
5. Notwithstanding the provisions of paragraphs 1 and 2, where a person – other than an agent of
an independent status to whom paragraph 7 applies – is acting on behalf of an enterprise and has,
and habitually exercises, in a Contracting State an authority to conclude contracts in the name of
the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in
respect of any activities which that person undertakes for the enterprise, unless the activities of
such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed
place of business, would not make this fixed place of business a permanent establishment under
the provisions of that paragraph.
6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting
State shall, except in regard to reinsurance, be deemed to have a permanent establishment in the
other State if it collects premiums in the territory of that other State or insures risks situated
therein through an employee or through a representative who is not an agent of an independent
status within the meaning of paragraph 7.
7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State
merely because it carries on business in that State through a broker, general commission agent or
any other agent of an independent status, provided that such persons are acting in the ordinary
course of their business.
8. The fact that a company which is a resident of a Contracting State controls or is controlled by
a company which is a resident of the other Contracting State, or which carries on business in that
other State (whether through a permanent establishment or otherwise), shall not of itself constitute
either company a permanent establishment of the other.
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Article 6.【INCOME FROM IMMOVABLE PROPERTY】[2003.05.29]
1. Income derived by a resident of a Contracting State from immovable property (including income
from agriculture or forestry) situated in the other Contracting State may be taxed in that other
State.
2. The term “immovable property” shall have the meaning which it has under the law of the
Contracting State in which the property in question is situated. The term shall in any case include
property accessory to immovable property, livestock and equipment used in agriculture and
forestry, rights to which the provisions of general law respecting landed property apply, usufruct of
immovable property and rights to variable or fixed payments as consideration for the working of,
or the right to work, mineral deposits, sources and other natural resources; ships and aircraft shall
not be regarded as immovable property.
3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting or use
in any other form of immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of
an enterprise and to income from immovable property used for the performance of independent
personal services.
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Article 7.【BUSINESS PROFITS】[2003.05.29]
1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the
enterprise carries on business in the other Contracting State through a permanent establishment
situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise
may be taxed in the other State but only so much of them as is attributable to that permanent
establishment.
2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on
business in the other Contracting State through a permanent establishment situated therein, there
shall in each Contracting State be attributed to that permanent establishment the profits which it
might be expected to make if it were a distinct and separate enterprise engaged in the same or
similar activities under the same or similar conditions and dealing wholly independently with the
enterprise of which it is a permanent establishment.
3. In determining the profits of a permanent establishment, there shall be allowed as deductions
expenses under the provisions of domestic law which are incurred for the purposes of the business
of the permanent establishment, including executive and general administrative expenses so
incurred, whether in the State in which the permanent establishment is situated or elsewhere.
4. No profits shall be attributed to a permanent establishment by reason of the mere purchase by
that permanent establishment of goods or merchandise for the enterprise.
5. For the purposes of the preceding paragraphs of this Article, the profits to be attributed to the
permanent establishment shall be determined by the same
method year by year unless there is good and sufficient reason to the contrary.
6. Where profits include items of income which are dealt with separately in other Articles of this
Agreement, then the provisions of those Articles shall not be affected by the provisions of this
Article.
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Article 8.【SHIPPING AND AIR TRANSPORT】[2003.05.29]
1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in
international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool,
a joint business or an international operating agency.
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Article 9.【ASSOCIATED ENTERPRISES】[2003.05.29]
1. Where
a) an enterprise of a Contracting State participates directly or indirectly in the management,
control or capital of an enterprise of the other Contracting State, or
b) the same persons participate directly or indirectly in the management, control or capital of
an enterprise of a Contracting State and an enterprise of the other Contracting State,
and in either case conditions are made or imposed between the two enterprises in their commercial
or financial relations which differ from those which would be made between independent
enterprises, then any profits which would, but for those conditions, have accrued to one of the
enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits
of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State-and taxes
accordingly-profits on which an enterprise of the other Contracting State has been charged to tax
in that other State and the profits so included are profits which would have accrued to the
enterprise of the first-mentioned State if the conditions made between the two enterprises had
been those which would have been made between independent enterprises, then that other State
shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In
determining such adjustment, due regard shall be had to the other provisions of this Agreement and
the competent authorities of the Contracting States shall consult each other.
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Article 10.【DIVIDENDS】[2003.05.29]
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the
other Contracting State may be taxed in that other State.
2. However, such dividends may also be taxed in the Contracting State of which the company
paying the dividends is a resident and according to the laws of that State, but if the recipient is
the beneficial owner of the dividends the tax so charged shall not exceed:
a) 5 percent of the gross amount of the dividends if the beneficial owner is a company which
holds directly at least 25 percent of the shares of the company paying the dividends;
b) 10 percent of the gross amount of the dividends if the beneficial owner is a company which
holds directly at least 10 percent of the shares of the company paying the dividends;
c) 15 percent of the gross amount of the dividends in all other cases.
This paragraph shall not affect the taxation of the company in respect of the profits out of which
the dividends are paid.
3. The term “dividends” as used in this Article means income from shares or other rights, not
being debt-claims, participating in profits, as well as income from other corporate rights which is
subjected to the same taxation treatment as income from shares by the laws of the State of which
the company making the distribution is a resident.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends,
being a resident of a Contracting State, carries on business in the other Contracting State of which
the company paying the dividends is a resident, through a permanent establishment situated therein,
or performs in that other State independent personal services from a fixed base situated therein,
and the holding in respect of which the dividends are paid is effectively connected with such
permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as
the case may be, shall apply.
5. Where a company which is a resident of a Contracting State derives profits or income from the
other Contracting State, that other State may not impose any tax on the dividends paid by the
company, except insofar as such dividends are paid to a resident of that other State or insofar as
the holding in respect of which the dividends are paid is effectively connected with a permanent
establishment or a fixed base situated in that other State, nor subject the company’s undistributed
profits to a tax on the company’s undistributed profits, even if the dividends paid or the
undistributed profits consist wholly or partly of profits or income arising in such other State.
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Article 11.【INTEREST】[2003.05.29]
1. Interest arising in a Contracting State and paid to a resident of the other Contracting State may
be taxed in that other State.
2. However, such interest may also be taxed in the Contracting State in which it arises and
according to the laws of that State, but if the beneficial owner of the interest is a resident of the
other Contracting State, the tax so charged shall not exceed 10 percent of the gross amount of the
interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State and derived
by the Government of the other Contracting State including political subdivisions and local
authorities thereof, the Central Bank of that other State or any financial institution performing
functions of a governmental nature or by any resident of the other Contracting State with respect
to debt-claim guaranteed or indirectly-financed by the Government of that other State including
political subdivisions and local authorities thereof, the Central Bank of that other State or any
financial institution performing functions of a governmental nature shall be exempt from tax in the
first-mentioned Contracting State.
4. For the purposes of paragraph 3, the terms “the Central Bank and financial institution performing
functions of a governmental nature” mean:
a) in Korea:
(i) the Bank of Korea;
(ⅱ) the Korea Export-Import Bank;
(ⅲ) the Korea Development Bank, and
(ⅳ) such other financial institution performing functions of a governmental nature as may be
specified and agreed upon in letters exchanged between the competent authorities of the
Contracting States;
b) in Nepal:
(i) Nepal Rastra Bank(Central Bank of Nepal);
(ⅱ) Nepal Industrial Development Corporation;
(ⅲ) Agriculture Development Bank, and
(ⅳ) such other financial institution performing functions of a governmental nature as may be
specified and agreed upon in letters exchanged between the competent authorities of the
Contracting States.
5. The term “interest” as used in this Article means income from debt-claims of every kind,
whether or not secured by mortgage and whether or not carrying a right to participate in the
debtor’s profits, and in particular, income from government securities and income from bonds or
debentures, including premiums and prizes attaching to such securities, bond or debentures.
6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the interest,
being a resident of a Contracting State, carries on business in the other Contracting State in which
the interest arises, through a permanent establishment situated therein, or performs in that other
State independent personal services from a fixed base situated therein, and the debt-claim in
respect of which the interest is paid is effectively connected with such permanent establishment or
fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
7. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a
political subdivision, a local authority or a resident of that State. Where, however, the person
paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting
State a permanent establishment or a fixed base in connection with which the indebtedness on
which the interest is paid was incurred, and such interest is borne by such permanent
establishment or fixed base, then such interest shall be deemed to arise in the State in which the
permanent establishment or fixed base is situated.
8. Where, by reason of a special relationship between the payer and the beneficial owner or
between both of them and some other person, the amount of the interest, having regard to the
debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the
payer and the beneficial owner in the absence of such relationship, the provisions of this Article
shall apply to the last-mentioned amount. In such case, the excess part of the payments shall
remain taxable according to the laws of each Contracting State, due regard being had to the other
provisions of this Agreement.
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Article 12.【ROYALTIES】[2003.05.29]
1. Royalties arising in a Contracting State and beneficially owned by a resident of the other
Contracting State may be taxed in that other State.
2. However, such royalties may also be taxed in the Contracting State in which they arise and
according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the
tax so charged shall not exceed 15 percent of the gross amount of the royalties.
3. The term “royalties” as used in this Article means payments of any kind received as a
consideration for the use of, or the right to use, any copyright of literary, artistic or scientific
work including cinematograph films or tapes for radio or television broadcasting, any patent, trade
mark, design or model, plan, secret formula or process, or for information concerning industrial,
commercial or scientific experience.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties,
being a resident of a Contracting State, carries on business in the other Contracting State in which
the royalties arise, through a permanent establishment situated therein, or performs in that other
State independent personal services from a fixed base situated therein, and the right or property in
respect of which the royalties are paid is effectively connected with such permanent establishment
or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall
apply.
5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a
political subdivision, a local authority or a resident of that State. Where, however, the person
paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting
State a permanent establishment or a fixed base in connection with which the liability to pay the
royalties was incurred, and such royalties are borne by such permanent establishment or fixed
base, then such royalties shall be deemed to arise in the State in which the permanent
establishment or fixed base is situated.
6. Where, by reason of a special relationship between the payer and the beneficial owner or
between both of them and some other person, the amount of the royalties, having regard to the
use, right or information for which they are paid, exceeds the amount which would have been
agreed upon by the payer and the beneficial owner in the absence of such relationship, the
provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess
part of the payments shall remain taxable according to the laws of each Contracting State, due
regard being had to the other provisions of this Agreement.
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Article 13.【CAPITAL GAINS】[2003.05.29]
1. Gains derived by a resident of a Contracting State from the alienation of immovable property
referred to in Article 6 and situated in the other Contracting State may be taxed in that other
State.
2. Gains from the alienation of movable property forming part of the business property of a
permanent establishment which an enterprise of a Contracting State has in the other Contracting
State or of movable property pertaining to a fixed base available to a resident of a Contracting
State in the other Contracting State for the purpose of performing independent personal services,
including such gains from the alienation of such a permanent establishment (alone or with the
whole enterprise) or of such fixed base, may be taxed in that other State.
3. Gains from the alienation of ships or aircraft operated in international traffic or movable
property pertaining to the operation of such ships or aircraft shall be taxable only in the
Contracting State of which the enterprise is a resident.
4. Gains from the alienation of shares of the capital stock of a company the property of which
consists directly or indirectly principally of immovable property situated in a Contracting State may
be taxed in that State.
5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4
shall be taxable only in the Contracting State of which the alienator is a resident.
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Article 14.【INDEPENDENT PERSONAL SERVICES】[2003.05.29]
1. Income derived by an individual who is a resident of a Contracting State in respect of
professional services or other activities of an independent character shall be taxable only in that
State unless:
a) he has a fixed base regularly available to him in the other Contracting State for the purpose
of performing his activities; or
b) he is present in that other Contracting State for a period or periods amounting to or
exceeding in the aggregate 183 days in any twelve month period commencing or ending in the
fiscal year concerned.
If he has such a fixed base or is present in that other Contracting State for aforesaid period or
periods, the income may be taxed in the other Contracting State but only so much of the income
as is attributable to that fixed base or is derived in that other Contracting State during the
aforesaid period or periods.
2. The term “professional services” includes especially independent scientific, literary, artistic,
educational or teaching activities as well as the independent activities of physicians, lawyers,
engineers, architects, dentists and accountants.
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Article 15.【DEPENDENT PERSONAL SERVICES】[2003.05.29]
1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar
remuneration derived by an individual who is a resident of a Contracting State in respect of an
employment shall be taxable only in that State unless the employment is exercised in the other
Contracting State. If the employment is so exercised, such remuneration as is derived therefrom
may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a
resident of a Contracting State in respect of an employment exercised in the other Contracting
State shall be taxable only in the first-mentioned State if:
a) the recipient is present in the other State for a period or periods not exceeding in the
aggregate 183 days in any twelve month period commencing or ending in the fiscal year
concerned;
b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other
State; and
c) the remuneration is not borne by a permanent establishment or a fixed base which the
employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an
employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of
a Contracting State shall be taxable only in that State.
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Article 16.【DIRECTORS’ FEES】[2003.05.29]
Directors’ fees and other similar payments derived by an individual who is a resident of a
Contracting State in his capacity as a member of the board of directors of a company which is a
resident of the other Contracting State may be taxed in that other State.
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Article 17.【ARTISTES AND SPORTSMEN】[2003.05.29]
1. Notwithstanding the provisions of Articles 14 and 15, income derived by an individual who is a
resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or
television artiste, or a musician, or as a sportsman, from his personal activities as such exercised
in the other Contracting State, may be taxed in that other State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsman in his
capacity as such accrues not to the entertainer or sportsman himself but to another person, that
income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting
State in which the activities of the entertainer or sportsman are exercised.
3. Notwithstanding the provisions of paragraphs 1 and 2 of this Article, income derived by
entertainers or sportsmen who are residents of a Contracting State from the activities exercised in
the other Contracting State under a special program of cultural exchange agreed upon between the
Governments of both Contracting States, shall be exempt from tax in that other State.
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Article 18.【PENSIONS, ANNUITIES & SOCIAL SECURITY PAYMENTS】[2003.05.29]
1. Subject to the provisions of paragraph 2 of Article 19, pensions, annuities or other similar
remuneration paid to an individual who is a resident of the Contracting State in consideration of
past employment shall be taxable only in that State.
2. The term “annuities “means a stated sum payable periodically at stated times during life or
during a specified or ascertainable period of time under an obligation to make the payments in
return for adequate and full consideration in money or money’s worth.
3. Notwithstanding the provisions of paragraph 1, pensions paid and other payments made under a
public scheme which is part of the social security systems of a Contracting State shall be taxable
only in that State.
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Article 19.【GOVERNMENT SERVICE】[2003.05.29]
1. a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a
local authority thereof to an individual in respect of services rendered to that State or subdivision
or authority shall be taxable only in that State.
b) However, such remuneration shall be taxable only in the other Contracting State if the
services are rendered in that State and the individual is a resident of that State who:
(i) is a national of that other State; or
( ) did not become a resident ⅱ of that State solely for the purpose of rendering the
services.
2. a) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision
or a local authority thereof to an individual in respect of services rendered to that State or
subdivision or authority shall be taxable only in that State.
b) However, such pension shall be taxable only in the other Contracting State if the individual
is a resident of, and a national of, that State.
3. The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in respect
of services rendered in connection with a business carried on by a Contracting State or a political
subdivision or local authority thereof.
4. The provisions of paragraphs 1 and 2 shall likewise apply in respect of remuneration or
pensions paid by:
a) in Korea:
(i) the Bank of Korea;
(ⅱ) the Korea Export-Import Bank;
(ⅲ) the Korea Development Bank;
(ⅳ) the Korea Trade-Investment Promotion Agency, and
(ⅴ) other institution performing functions of a governmental nature as may be specified and
agreed upon in letters exchanged between the competent authorities of the Contracting States;
b) in Nepal:
(i) Nepal Rastra Bank (Central Bank of Nepal);
(ⅱ) Nepal Industrial Development Corporation;
(ⅲ) Agriculture Development Bank, and
(ⅳ) such other financial institution performing functions of a governmental nature as may be
specified and agreed upon in letters exchanged between the competent authorities of the
Contracting States.
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Article 20.【STUDENTS】[2003.05.29]
1. A student or business apprentice who is or was a resident of a Contracting State immediately
before visiting the other Contracting State and who is present in that other State solely for the
purpose of his education or training, shall be exempt from tax in that other State on:
a) payments made to him by persons residing outside that other State for the purposes of his
maintenance, education or training; and
b) remuneration from employment in that other State, in an amount not exceeding 10,000
United States dollars or its equivalent in Korean currency or in Nepalese currency during any
calendar year provided that such employment is directly related to his studies or is undertaken for
the purpose of his maintenance.
2. The benefits of this Article shall extend only for such period of time as may be reasonably or
customarily required to complete the education or training undertaken, but in no event shall any
individual have the benefits of this Article for more than five consecutive years from the date of
his first arrival in that other Contracting State.
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Article 21.【TEACHERS AND RESEARCHERS】[2003.05.29]
1. A professor, teacher or researcher who makes a temporary visit to a Contracting State for the
purpose of teaching or conducting research at a university, college, school or other recognized
educational institution and who is, or immediately before such visit was, a resident of the other
Contracting State shall be exempted from tax in the first-mentioned State for a period not
exceeding two years in respect of remuneration for such teaching or research.
2. This Article shall not apply to remuneration which a professor or teacher receives for
conducting research if the research is undertaken primarily for the private benefit of a specific
person or persons.
——————————————————————————–
Article 22.【OTHER INCOME】[2003.05.29]
1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the
foregoing Articles of this Agreement shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income from immovable
property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of
a Contracting State, carries on business in the other Contracting State through a permanent
establishment situated therein, or performs in that other State independent personal services from a
fixed base situated therein, and the right or property in respect of which the income is paid is
effectively connected with such permanent establishment or fixed base. In such case the provisions
of Article 7 or Article 14, as the case may be, shall apply.
——————————————————————————–
Article 23.【RELIEF FROM DOUBLE TAXATION】[2003.05.29]
1. Subject to the provisions of Korean tax law regarding the allowance as a credit against Korean
tax of tax payable in any country other than Korea:
a) Where a resident of Korea derives income from Nepal, which may be taxed in Nepal in
accordance with the provisions of this Agreement, Korea shall allow, subject to its laws, an amount
equal to income tax paid or payable in Nepal as a credit from the tax on the income of that1.
Subject to the provisions of Korean tax law regarding the allowance as a credit against Korean tax
of tax payable in any country other than Korea:
a) Where a resident of Korea derives income from Nepal, which may be taxed in Nepal in
accordance with the provisions of this Agreement, Korea shall allow, subject to its laws, an amount
equal to income tax paid or payable in Nepal as a credit from the tax on the income of that
resident. The amount of credit shall not, however, exceed that part of income tax as computed
before the credit is given, which is appropriate to that income taxed in Nepal.
b) Notwithstanding the provisions of sub-paragraph a), there shall be deemed to have been
paid by the Korean resident the amount which would have been paid as Nepal tax under the laws
of Nepal and in accordance with this Agreement if the Nepal tax had not been reduced or
exempted in Nepal in accordance with any special incentive measures designed to promote
economic development in Nepal, which are effective on the date of signature of this Agreement or
which may be introduced in the future in laws relating to Nepal tax in place of, or in addition to,
the existing measures, provided that an agreement is made between the competent authorities of
the two Contracting States in respect of the scope of the benefit accorded to the taxpayer by the
said measures.
c) Where a company which is a resident of Korea owns not less than 20 per cent of the total
shares issued by a company which is a resident of Nepal, Korea shall take into account, in
determining the tax to be paid in Korea, the tax paid or payable by the second-mentioned company
in respect of the profits out of which the dividend is paid.
2. Subject to the provisions of Nepal tax law regarding the allowance as a credit against Nepal tax
of tax payable in any country other than Nepal:
a) Where a resident of Nepal derives income from Korea, which may be taxed in Korea in
accordance with the provisions of this Agreement, Nepal shall allow, subject to its laws, an amount
equal to income tax paid or payable in Korea as a credit from the tax on the income of that
resident. The amount of credit shall not, however, exceed that part of income tax as computed
before the credit is given, which is appropriate to that income taxed in Korea.
b) Where a company which is a resident of Nepal owns not less than 20 per cent of the total
shares issued by a company which is a resident of Korea, Nepal shall take into account, in
determining the tax to be paid in Nepal, the tax paid or payable by the second-mentioned company
in respect of the profits out of which the dividend is paid. resident. The amount of credit shall not,
however, exceed that part of income tax as computed before the credit is given, which is
appropriate to that income taxed in Nepal.
b) Notwithstanding the provisions of sub-paragraph a), there shall be deemed to have been
paid by the Korean resident the amount which would have been paid as Nepal tax under the laws
of Nepal and in accordance with this Agreement if the Nepal tax had not been reduced or
exempted in Nepal in accordance with any special incentive measures designed to promote
economic development in Nepal, which are effective on the date of signature of this Agreement or
which may be introduced in the future in laws relating to Nepal tax in place of, or in addition to,
the existing measures, provided that an agreement is made between the competent authorities of
the two Contracting States in respect of the scope of the benefit accorded to the taxpayer by the
said measures.
c) Where a company which is a resident of Korea owns not less than 20 per cent of the total
shares issued by a company which is a resident of Nepal, Korea shall take into account, in
determining the tax to be paid in Korea, the tax paid or payable by the second-mentioned company
in respect of the profits out of which the dividend is paid.
2. Subject to the provisions of Nepal tax law regarding the allowance as a credit against Nepal tax
of tax payable in any country other than Nepal:
a) Where a resident of Nepal derives income from Korea, which may be taxed in Korea in
accordance with the provisions of this Agreement, Nepal shall allow, subject to its laws, an amount
equal to income tax paid or payable in Korea as a credit from the tax on the income of that
resident. The amount of credit shall not, however, exceed that part of income tax as computed
before the credit is given, which is appropriate to that income taxed in Korea.
b) Where a company which is a resident of Nepal owns not less than 20 per cent of the total
shares issued by a company which is a resident of Korea, Nepal shall take into account, in
determining the tax to be paid in Nepal, the tax paid or payable by the second-mentioned company
in respect of the profits out of which the dividend is paid.
——————————————————————————–
Article 24.【NON-DISCRIMINATION】[2003.05.29]
1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any
taxation or any requirement connected therewith, which is other or more burdensome than the
taxation or connected requirements to which nationals of that other State in the same
circumstances, are or may be subjected. This provision shall, notwithstanding the provisions of
Article 1, also apply to persons who are not residents of one or both of the Contracting States.
2. The taxation on a permanent establishment or a fixed base which an enterprise of a Contracting
State has in the other Contracting State shall not be less favorably levied in that other State than
the taxation levied on enterprises of that other State carrying on the same activities. This provision
shall not be construed as obliging a Contracting State to grant to residents of the other Contracting
State any personal allowances, reliefs and reduction for taxation purposes on account of civil status
or family responsibilities which it grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or
paragraph 4 of Article 12 apply, interest, royalties and other disbursements paid by an enterprise
of a Contracting State to a resident of the other Contracting State shall, for the purpose of
determining the taxable profits of such enterprise, be deductible, under the same conditions as if
they had been paid to a resident of the first-mentioned State.
4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled,
directly or indirectly, by one or more residents of the other Contracting State, shall not be
subjected in the first-mentioned State to any taxation or any requirements connected therewith
which is other or more burdensome than the taxation and connected requirements to which other
similar enterprises of the first-mentioned State are or may be subjected.
5. The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of
every kind and description.
——————————————————————————–
Article 25.【MUTUAL AGREEMENT PROCEDURE】[2003.05.29]
1. Where a person considers that the actions of one or both of the Contracting States result or will
result for him in taxation not in accordance with the provisions of this Agreement, he may,
irrespective of the remedies provided by the domestic law of those States, present his case to the
competent authority of the Contracting State of which he is a resident or, if his case comes under
paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case
must be presented within three years from the first notification of the action resulting in taxation
not in accordance with the provisions of the Agreement.
2. The competent authority shall endeavor, if the objection appears to it to be justified and if it is
not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with
the competent authority of the other Contracting State, with a view to the avoidance of taxation
which is not in accordance with the Agreement.
3. The competent authorities of the Contracting States shall endeavor to resolve by mutual
agreement any difficulties or doubts arising as to the interpretation or application of the
Agreement. They may also consult together for the elimination of double taxation in cases not
provided for in the Agreement.
4. The competent authorities of the Contracting States may communicate with each other directly
for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems
advisable in order to reach an agreement to have an oral exchange of opinions, such exchange
may take place through a Commission consisting of representatives of the competent authorities of
the Contracting States.
——————————————————————————–
Article 26.【EXCHANGE OF INFORMATION】[2003.05.29]
1. The competent authorities of the Contracting States shall exchange such information as is
necessary for carrying out the provisions of this Agreement or of the domestic laws of the
Contracting States concerning taxes covered by the Agreement, insofar as the taxation thereunder
is not contrary to the Agreement. The exchange of information is not restricted by Article 1. Any
information received by a Contracting State shall be treated as secret in the same manner as
information obtained under the domestic laws of that State and shall be disclosed only to persons
or authorities (including courts and administrative bodies) concerned with the assessment or
collection of, the enforcement or prosecution in respect of, or the determination of appeals in
relation to, the taxes covered by the Agreement. Such persons or authorities shall use the
information only for such purposes. They may disclose the information in public court proceedings
or in judicial decisions.
2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting
State the obligation:
a) to carry out administrative measures at variance with the laws and administrative practice of
that or of the other Contracting State;
b) to supply information which is not obtainable under the laws or in the normal course of the
administration of that or of the other Contracting State;
c) to supply information which would disclose any trade, business, industrial, commercial, or
professional secret or trade process, or information, the disclosure of which would be contrary to
public policy (order public).
——————————————————————————–
Article 27.【MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS】[2003.05.29]
Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or
consular posts under the general rules of international law or under the provisions of special
agreements.
——————————————————————————–
Article 28.【ENTRY INTO FORCE】[2003.05.29]
1. Each Contracting State shall notify the other of the completion of the procedures required by its
law for the entering into force of this Agreement. The Agreement shall enter into force on the
later of the notifications.
2. The provisions of this Agreement shall have effect:
a) in Korea:
(i) in respect of taxes withheld at source, for amounts payable on or after the first day of
January in the first calendar year following that in which this Agreement enters into force;
(ⅱ) in respect of other taxes, for the taxable year beginning on or after the first day of
January in the first calendar year following that in which this Agreement enters into force;
b) in Nepal:
(i) in respect of taxes withheld at source or advance tax, for amounts payable on or after
the first day of Nepalese fiscal year next following the date of the entry into force of this
Agreement;
( ) in respect of taxes on income derived ⅱ on or after the first day of the Nepalese fiscal
year next following the date of the entry into force of this Agreement.
——————————————————————————–
Article 29.【TERMINATION】[2003.05.29]
1. This Agreement shall continue in effect indefinitely but either Contracting State may, on or
before the thirtieth day of June of any calendar year beginning after the expiration of a period of
five years from the date of its entry into force, give to the other Contracting State a notice of
termination in writing through diplomatic channels.
2. The provisions of this Agreement shall cease to have effect:
a) in Korea:
(i) in respect of taxes withheld at source, for amounts payable on or after the first day of
January in the first calendar year following that in which the notice is given;
(ⅱ) in respect of other taxes, for the taxable year beginning on or after the first day of
January in the first calendar year following that in which the notice is given;
b) in Nepal:
(i) in respect of taxes withheld at source or advance tax, for amounts payable on or after
the first day of Nepalese fiscal year next following the date on which the notice is given;
(ⅱ) in respect of taxes on income derived on or after the first day of the Nepalese fiscal
year next following the date on which the notice is given.
IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments,
have signed this Agreement.
Done in duplicate at Seoul this 5th day of October 2001, in the Korean, Nepali, and English
languages, all texts being equally authentic. In case of divergence of interpretation, the English text
shall prevail.
FOR THE GOVERNMENT OF FOR HIS MAJESTY’S GOVERNMENT
THE REPUBLIC OF KOREA OF NEPAL
——————————————————————————–
[2003.05.29]
PROTOCOL
On signing the Agreement between the Republic of Korea and the Kingdom of Nepal for the
Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
Income, the undersigned have agreed that the following provisions shall form an integral part of the
Agreement.
With reference to paragraph 2 of Article 5,
The term “permanent establishment” includes a warehouse in relation to a person habitually
providing storage facilities for others.
With reference to paragraph 3 of Article 7.
The deduction shall not be allowed in respect of amounts, if any, paid (otherwise than towards
reimbursement of actual expenses) by a permanent establishment to the head office of the
enterprise or any of its other offices, by way of royalties, fees or other similar payments in return
for the use of patents or other rights, or by way of commission for specific services performed or
for management, or, except in the case of a banking enterprise, by way of interest on monies lent
to the permanent establishment, Likewise on account shall be taken, in the determination of the
profits of a permanent establishment, for amounts charged (otherwise than towards reimbursement
of actual expenses), by the permanent establishment to the head office of the enterprise or any of
its other offices, by way of royalties, fees or other similar payments in return for the use of
patents or other rights, or by way of commission for specific services performed or for
management, or, except in the case of a banking enterprise, by way of interest on monies lent to
the head office of the enterprise of any of its other offices.
With reference to paragraph 2 of article 10 and paragraph 2 of Article 12.
There shall be immediately substituted for the rate of 5, 10, or 15 per cent specified in paragraph
2 of Article 10 and for the rate 15 percent specified in paragraph 2 of Article 12 such lower rates
as may be agreed upon between nepal and any other country in any Agreement for the avoidance
of double taxation and prevention of fiscal evasion with respect to taxes on income concluded
between Nepal and that other country subsequent to this Agreement.
With reference to sub-paragraph 1b) of Article 23.
The special incentive measures designed to promote economic development in Nepal are the
measures under the Income Tax Act, the Industrial Enterprise Act, the Foreign Investment and
Technology Transfer Act, the Electricity Act and other related laws, it is understood that the
provisions of sub-paragraph 1 b) of Article 23 shall not be applied to a resident of Korea whose
income in derived from engaging in the business activities in the financial sector or from third
states. This Provision shall cease to have effect in respect of income derived by a resident of
Korea in any taxable year beginning after December 31, 2003. However, the competent authorities
of both Contracting States may consult each other and agree upon extending this period up to any
further period.
IN WITNESS WHEREOF, the undersigned, duly authorized thereto by their respective Governments,
have signed this Protocol.
Done in duplicate at Seoul this 5th day of October 2001, in the Korean, Nepali, and English
Languages, all texts being equally authentic. In case of divergence of interpretation, the English
text shall prevail.
FOR THE GOVERNMENT OF THE REPUBLIC OF KOREA
FOR HIS MAJESTY’S GOVERNMENT OF NEPAL
——————————————————————————–

http://www.hikot.com/index.php?do=/nepal-south-korea-tax-treaty/

Nepal Taxation 2011-2012 this link http://www.hikot.com/index.php?do=/nepal-taxation-2011-2012/

Nepal Taxation Guide 2011-2012 PDF Download

South Korea – Nepal Tax Treaty PDF Download

Revenue Recognition for Construction

JPIA (Junior Philippine Institute of Accountants) — Wed, 02 Mar 2011 07:29:38 +0000

Most common accounting practices for revenue recognition is by invoice method but for recognizing revenue for construction companies the common and most acceptable method is progress method which could be computed base on its project completion.

E.g. Contract Value $ 1,000,000.00
Contractors Margin is 85% ($ 850,000.00) or total estimated cost

Invoice 1 : $ 200,000.00
Cost : $ 150,000.00

To compute the revenue

Cost Incurred (Current) / Total Estimated Cost = Percent Complete (Current Period) x Total Revenue = Revenue Recognized (Current Period)

Revenue = $150,000/850,000 x 1,000,000 = $176,471.00

GAAP has carved out a special niche for construction contractors. While there is no FASB Statement for this area, AICPA Accounting Research Bulletin (ARB) No. 45, Long-Term Construction-Type Contracts, (1955) and AICPA Statement of Position (SOP) 81-1, Accounting for Performance of Construction-Type and Certain Production-Type Contracts, (1981) address it specifically. There is also an excellent AICPA Audit and Accounting Guide, Construction Contractors (see Resource IND 1).

Because most construction contracts by their nature are long-term, the underlying accounting principle known as matching — expenses follow revenues — would be violated if the revenue from the contract were recognized upon contract execution or sale of the services. There are two methods of revenue recognition are allowed under the preceding pronouncements for construction contractors.
One is percentage of completion (PC) method and the other is completed contract (CC) method. Under the PC method, the construction contractor recognizes revenue over the life of the construction contract based on the degree of completion: 50% completion means recognition of one-half of revenues, costs, and income. Under the CC method, all revenues, costs, and income are recognized only at completion of the construction project, ordinarily at the end of the construction contract.

SOP 81-1 requires that the PC method be used in lieu of the CC method when all of the following are present:

1. 1. Reasonably reliable estimates can be made of revenue and costs;

2. 2. The construction contract specifies the parties’ rights as to the goods, consideration to be paid and received, and the resulting terms of payment or settlement;

3. 3. The contract purchaser has the ability and expectation to perform all contractual duties; and

4. 4. The contract contractor has the same ability and expectation to perform.

The CC method is used in rare circumstances, which are set forth in SOP 81-1 to be any of the following:

1. 1. The contract is of a short duration (not defined), Such as 24 months or less. As a result, the recognized revenue would not differ under the PC or CC methods;

2. 2. The contract violates any one of the items 1 through 4 above; or

3. 3. The contract’s project exhibits documented extraordinary, nonrecurring business risks (such as extinguishing oil well fires in a country while hostilities are continuing).

In applying these revenue recognition methods, it is important that the following five items be kept in mind:

• Generally, each construction contract is treated as a profit center, with its own revenues, costs, and income. There are, however, circumstances in which multiple contracts, change orders, or options, for example, create the issue of whether to combine contracts into one profit center or to segment the contracts into separate profit centers.

SOP 81-1 sets forth the criteria for combining and segmenting construction contracts. As a general rule, the more interrelated and cohesive a project — for example, through substantial common costs, a single buyer, or concurrent performance of steps in the project — the more the scales tip in favor of combining. In contrast, when 1) separate project components have bids distinct from the entire project; 2) the buyer may choose to accept any, all, or more of the bids; and 3) the components of the project have the approximate revenues, costs, and income of a stand-alone project, then segmenting the contract is permissible. For such segmentation, SOP 81-1 has additional requirements that should be reviewed.

• GAAP requires that the accrual method be used for all reported billings and costs and losses.

• Cost allocation is based on direct and indirect costs as well as construction period interest.

• Assets are represented by underbillings (estimated costs and earnings exceed billings) whereas liabilities are shown as overbillings (billings exceed estimated costs and earnings).

• Consolidation theory applies to investments in construction projects or ventures per AICPA ARB No. 51, Consolidated Financial Statements; FASB Statement No. 94, Consolidation of All Majority-owned Subsidiaries — an amendment of ARB No. 51, with related amendments of APB Opinion No. 18 and ARB No. 43, Chapter 12; and, most importantly, APB Opinion No. 18, The Equity Method of Accounting for Investments in Common Stock. Because of potential changes in this area, the AICPA website www.aicpa.org and FASB website www.fasb.org should be consulted.

There are several modifications to revenue recognition rules for government contractors. These modifications should be reviewed by those engaged in federal government contracting.

Hikot’s Features are not in Facebook

JPIA (Junior Philippine Institute of Accountants) — Wed, 02 Mar 2011 05:56:39 +0000

Hikot- Pinoy Social Logo

Since the announced February 14 Launching of hikot.com we didn’t hear anymore feedback from them but recently, they come out to speak of what had happened and according to the Hikot insider, they are happy of the result because Hikot users were not just become Hikot addict but also discovered there unannounced features.

The sociability of the Filipinos will never fade and it is a Filipino culture. Before the existence of social network site like Friendster and Facebook or even Hikot; Filipinos are already sociable reasons why the Philippines become the TEXT or SMS Capital of the World which is now added another title as the Philippines is the Social Network Capital of the World. Filipinos are willing to spend times just to be connected with their love ones from anywhere in the world. For more than 9 Million Filipinos living abroad which keep connected to their family and Relatives in the Philippines; Social Network like Hikot or Facebook is really needed. From the old system of postal mail, to MIRC in 1990’s YM & (Yahoo Messenger) to SMS / TEXT and Email in 2000’ now it is Social Network Generation.

Though Hikot is still new in the Social Network, they are trying to do their best to gain percentage of users from around Asia and they gain a good impact from China. Most of the newly registered users of Hikot are from China; which maybe QQ users who are interested to try a new diversion of QQ found it in Hikot.

Hikot did not publish their features yet but it is not so far from what Facebook have. Hikot features which could not be found in Facebook are the following;

Forum

Classifieds

Blog

Events

Polls and

Bulletins

Hikot and Facebook are having in common for the following:

* Notification bubble. Facebook Notification could be found in the upper left of the screen which displaying in red and showing numbers of notices while Hikot have such feature in the lower right beside the online chat base feature as in Facebook.

* For the Photo viewing of Facebook they use a slide style but in Hikot, they use Movie Flow system which you are like watching or loading a movie file in a pup-up or bubble style.

Other features are almost in common except for the features which exist in Hikot and not in Facebook.

2011 Valentines – “Hikot | We build connection” Launching

JPIA (Junior Philippine Institute of Accountants) — Mon, 21 Feb 2011 08:01:11 +0000

“Hikot | We build connection”

What can you say since the hikot social network finally concluded to get online. “Hikot | We build connection” is the first social network which could be claim by Visayas and Mindanao as their owned. Hikot is a “Binisaya” term in the Philippines which means “tie” “bind” or “knot” another version of social network originated in the Philippines. Binisaya Language is one of the highly spoken for the largest population of almost 50 Million Filipinos in the Philippines.

Base on the latest survey, most people of the Philippines are fan of social network and very close to the recent update of the western countries. The Philippines is the only country in Asia who patronizes “Twitter” and “Facebook”. Though Friendster is the pioneer social network in the country, it was overtaken by Facebook now but what could this HIKOT’s standing with the big giant rival in social network?
“Hikot | We build connection” with their website http://www.hikot.com/ is now online and trying to compete even late with the 2 leading giants in social network. Hikot’s founder is positive to overtake the 2 social networking giants by the end of 2011 but recently the membership of the hikot is still very slow.

If the Hikot would become dominant in the Philippines for social network then most probably it will crawl to most part of Asia and around the globe because of Millions of OFW or Overseas Filipino Workers abroad who uses social network to connect with their family.

World’s first biggest underwater resort hotel soon to rise in Palawan Philippines

JPIA (Junior Philippine Institute of Accountants) — Sat, 15 Jan 2011 14:32:32 +0000

The Philippines is all set to embrace a futuristic undersea project to rival those in Maldives, Dubai and Fiji, according to a Filipino team of developer and architects, which is set to build an underwater resort hotel in Palawan.

Dubbed as the Coral World Park, this multibillion-peso project will set the record as Asia’s first underwater resort development and the biggest undersea living in the world once the project is completed by 2013.

Picture this: You wake up to a picture perfect view of frivolously swimming manta rays and fishes or hold a meeting in a restaurant submerged in the pristine waters. Say what? All this isn’t science fiction according to an all-Filipino team behind the project.

Taking the helm is Singapore-based businessman Paul Monozca, who is known for his advocacies of helping Filipino sports teams and the overseas remittance business. Partnering with Monozca is renowned eco-architect Jose Pinggoy Manosa, who will take charge of the architectural design of the Coral World Park.

Its high time we brought sustainable development underwater because there have been similar projects elsewhere in the world that have been proven successful,” Monozca told Inquirer Property in an exclusive interview Wednesday.

He cited global warming and the rising water levels as factors that pushed him to look into the possibility of exploring the readiness of the country for this kind of revolutionary development.

Pegged at some $150 million, the undersea structure takes pride in its 24 undersea suites or pods called Anemones,” which are submerged 60 feet below sea level with a fascinating 270-degree view of the sea. The 15-foot-high Anemones will be built by a US firm that specializes in submarines.

Several units of these Anemones will be open for public viewing at reasonable rates while majority are for ownership. Each 50-square-meter Anemone (the size of two-bedroom condo unit) can be customized per owner’s preference. It can be used as a private villa, a receiving or entertainment room that could cater to as many as 15 people.

Filipino ingenuity

How can one move from one pod/suite to another? The Coral World Park will be built with submarine technology. The mode of transport will be through glass bottom mini-submarines to be powered by the first mobile hydropower system, which generates up to 1 megawatt of electricity. This will use a patented water recycling and pressure chamber invented by an all-Filipino team of engineers, Monozca said.

The project will show to the world Filipino ingenuity as 80 percent of the project will be run and manned by Filipinos, from engineers to architects down to personnel,” Monozca said. When completed, the proposed underwater habitat will be the biggest in the world.

Also part of the futuristic project is a 50-bedroom on land boutique hotel complete with amenities like casinos, spa, business center and an underwater restaurant to be named Starfish,” which could seat as many as 200 people in its 600-square-meter dining area. A seahorse-shaped science center aptly called Seahorse Science Center will be built for tourists and will serve as the park’s marine observatory and conservation center showcasing the richness of marine life in the Philippines.

The project is expected to pour in billions of investments and will help create thousands of jobs for the people in Palawan and neighbouring provinces.

Conservation tourism

Funding will come from Monozca’s Monaco-based group, which counts investors from the United States, the Middle East and Russia. As an aggressive venture in ecotourism business, the project also aims to replenish the coral reefs in the area and would advocate conservation tourism in the country.

Monozca related that everything has been in the planning stage since last year. He identified a group of islands in Coron as the site for development owing to its perfect geography, clear and cove-protected waters and rich marine life. The islands of Palawan hardly experience earthquakes and are not prone to visiting typhoons that occasionally hit the country.

The construction is set to start soon and will be completed in two years, according to Manosa, who said this would be my biggest project so far in my professional career.” Manosa is behind some of the biggest projects like the San Miguel Building constructed in the 1980s and the Brent International School.

I was overwhelmed myself when the project was offered to me. Even my family is excited about this; my grandchildren are asking when they could visit the underwater resort,” Manosa said.

The group dispelled fears of security as the whole resort will be tightly guarded. The proponents also envision a cashless system of transaction as everything will be made via specially issued bracelet cards similar to the function of a credit card.

The group promised strict adherence to protect the environment and the biodiversity of Palawan. They said no marine life will be harmed during the course of its construction to its operations.

Bayan Ko

JPIA (Junior Philippine Institute of Accountants) — Fri, 11 Jun 2010 13:18:57 +0000

Bayan Ko
(My Country)

Ang bayan kong Pilipinas
Lupain ng ginto’t bulaklak
Pag-ibig na sa kanyang palad,
Nag-alay ng ganda’t dilag,

At sa kanyang yumi at ganda,
Dayuhan ay naghalina;
Bayan ko, binihag ka,
Nasadlak sa dusa

Chorus:
Ibon mang may layang lumipad
Kulungin mo at umiiyak
Bayan pa kayang sakdal-dilag
Ang ‘di magnasang makaalpas?

Pilipinas kong minumutya,
Pugad ng luha at dalita
Aking adhika,
Makita kang sakdal laya.

[Musical Interlude]

Repeat Chorus:
Ibon mang may layang lumipad
Kulungin mo at umiiyak
Bayan pa kayang sakdal-dilag
Ang ‘di magnasang makaalpas?

Pilipinas kong minumutya,
Pugad ng luha at dalita
Aking adhika,
Makita kang sakdal laya…..

Junior Philippine Institute of Accountants (JPIA)

JPIA (Junior Philippine Institute of Accountants) — Mon, 27 Oct 2008 06:07:23 +0000

Welcome to JPIA Online!..

What is JPIA?

JPIA stands for stands for Junior Philippine Institute of Accountants (JPIA).

The Junior Philippine Institute of Accountants (JPIA) represents the world for the young accountants in the Philippines. JPIA is an organization established to develop its members as responsible, well-rounded individuals. It is likewise instituted to promote, to organize, and to coordinate activities for the welfare of the students and to nurture them not just a good student in their respective campuses but to their community as well. JPIA aims for solidarity and harmony among its members. It also aims to involve the members in all its activities by ensuring their active participation from the planning to the implementation stage. JPIA is a special and highly esteemed organization of the Philippines which is created only and exclusively for the students of Bachelor of Science in Accountancy (BSA) course in the exclusive public and private colleges and universities of the country which are granted an approval and accreditation from the college and university standards governing authority of the Philippines, the Commission of Higher Education (CHED).

It such called a very special organization for the BS Accountancy students because of the highest standards sets to the colleges and universities by the government to offer such course. Students who are admitted to take the course of Bachelor of Science in Accountancy have passed series of tough and thorough screening and examinations in different stages of their level. More often, Accountancy students in the Philippines are considered as the group of bright and genius student for surviving the screenings and tough examinations.

VISION..

JPIA envision as a professional student organization that serves as the training ground in the development of member through quality activities promoting dynamic interaction and well-roundedness of members. JPIA aims to develop dynamic, honest, God abiding, young professionals in the field of accountancy.

MISSION…

JPIA commit themselves for the fulfillment of their vision so that we may become competent, responsible, and dynamic and God abiding accountants responding to the challenges of the time.

ACCOUNTANCY SCREENING PROCESS (Philippine Government Standards)

For the freshmen

Medical Examination (Student must be physically and mentally fit to enroll the course)
GPA during High school must be very good
Must have a good moral character (This is required in performing their actual jobs. Philippine Accountants must be honest, independent and with high integrity)
Must passed the college/ university entrance test
Must have a higher to highest score in the college / university entrance test
Must passed the qualifying test for the Bachelor of Science in Accountancy (BSA) course.
In the test, it is required that the applicant must have to passed at a high rating for the major subjects intended for BSA Course including; Algebra, trigonometry, calculus, physics, chemistry and other semi major subjects . Failure of this requirement would not be admitted to take Bachelor of Science in Accountancy while passing the required procedure could not directly enroll for the course of Bachelor of Science in Accountancy but only for the first step. The door is open for them to enroll Associate in Accountancy Course.

They could have the chance to become a member of JPIA if they will survive the first 2 semester.

For the juniors & sophomores

Juniors and sophomores are eligible to be a member of the Junior Philippine Institute of Accountants (JPIA)
After 2 year of study for the Associate in Accountancy Course, they must have to take a qualifying examination for the next level. This test is more getting harder to test the student’s ability and learning with the course.
The examination is a qualifying examination for Bachelor of Science in Accounting Technology (BSAT).
The test is a qualifying examination for Bachelor of Science in Accounting Technology (BSAT)

Failure to pass the qualifying examination; the student would be advice to shift to another business related course such as Bachelor of Science in Marketing, Management, Economics and Finance. Since BS in Accountancy has a semi major in Management, Economics, Marketing and Finance, student who failed to passed the qualifying exam would be consider as feeble enough to survive for the different semi majors plus the full major of Accountancy and business laws.

For seniors

Preliminary requirements to take the final stage are another qualifying examination for the course of Bachelor of Science in Accountancy (BSA).
This is the final stage of this course.Failure to pass the qualifying test for the BSA course would not allow them to continue for the BS Accountancy so their final highest achievement for accounting study is just Bachelor of Science in Accounting Technology (BSAT)..
After graduation of the BSA course, the student could have a Special Order (S.O.) from the Commission on Higher Education (CHED), which S.O. would be reflected in their Diploma, Transcript of records and a recognition and requirement for them to be allowed to take the Certified Public Accountant Licensure Examination (CPA – LE).
Passing the CPA – LE will make them a Certified Public Accountant or CPA
For more information about the JPIA Philippines,

Please join the JPIA online Network

http://www.hikot.com/index.php?do=/jpia/

Please contact us:

Junior Philippine Institute of Accountants (JPIA)
Philippines.

Email the webmaster at:
webmaster023@live.com
http://www.jpia.wordpress.com
http://www.hikot.com/index.php?do=/jpia/

More Sources (Links)

P I C P A
(PICPA) Philippine Institute of Certified Public Accountants
Association of Philippine CPAs providing Accounting information and updates to CPAs
http://www.picpa.com.ph

N F J P I A
(NFJPIA) National Federation of Junior Philippine Institute of Accountants
Association of Bachelor of Science in Accountancy students in all Universities and Colleges in the Philippines
http://www.nfjpia.com/

Board of Accountancy
Professional Regulation Commission | Board of Accountancy
Government Regulations for practicing accountancy
http://www.pboa.com/

J P I A
(JPIA) Junior Philippine Institute of Accountants
Association of Bachelor of Science in Accountancy students in all Universities and Colleges in the Philippines