The term “employed thereat” become interpreted through the BIR as requiring a foreign employment settlement. Impliedly,
a trifling secondment of an employee, regardless of the duration of term, might no longer fulfill the condition of having an “employment thereat.” This new interpretation of the BIR has critical implications to the more and more worldwide Filipino employees who are now faced with having to pay taxes both abroad and inside the Philippines.
Aside from selling the worldwide mobilization of personnel, taxpayers and employers have to also keep in mind the provisions of secondment agreements and its impact at the tax obligations of each the worker and the corporation. This will manual taxpayers on the appropriate remittance of taxes on earnings earned from paintings abroad.