Consularized copy of the certificate of foreign registration/incorporation/association of the NRFC. But with the accession of the Philippines to the Apostille Convention, there will be no need to consularize the certificate of registration or any other document from almost all countries.
Similarly, if the services are performed in the Philippines, the payment to the NRFC will be subject to final withholding VAT of 12 percent on gross receipts.
8567, June 8, 2016), the Court of Tax Appeals (CTA) en banc ruled that the service of providing satellite air transmission by an NRFC to a Philippine entity is considered income from sources within the Philippines because such service could not have been consummated without the use of a gateway facility/server located in the Philippines, even though all services were actually rendered by the NRFC outside the Philippines (i.e., in Indonesia and in outer space).
Accordingly, the company will merge with and into its subsidiary NRFC Sub-REIT Corp and thereafter the surviving entity will be NorthStar Realty Finance Corp that will then effect the reverse stock split and the distribution, in which each NorthStar Realty common stockholder receives shares of NSAM common stock on a one-for-one basis, after giving effect to the one-for-two reverse stock split.