On 21 March 2016, the Philippine Court of Tax Appeals issued its decision concerning the availability of treaty benefits when an application for benefits has not been properly submitted. The case involved Lufthansa's Philippine branch and Lufthansa's gross Philippine billings for online activities in 2008. In its tax return for 2008, Lufthansa applied a 1.5% rate for its billings for online activities as provided for under Article 8 (Shipping and Air Transport) of the 1983 Germany-Philippines tax treaty. However, the Philippine tax authorities (BIR) took the position that because Lufthansa had not applied for treaty relief as per Revenue Memorandum...