2015 Taxation Law, Q2

Mr. A, a citizen and resident of the Philippines, is a professional boxer. In a professional boxing match held in 2013, he won prize money in United States (US) dollars equivalent to P300,000,000.
a) Is the prize money paid to and received by Mr. A in the US taxable in the Philippines? Why? (2%)
b) May Mr. A’s prize money qualify as an exclusion from his gross income? Why? (2%)
c) The US already imposed and withheld income taxes from Mr. A’s prize money. How may Mr. A use or apply the income taxes he paid on his prize money to the US when he computes his income tax liability in the Philippines for 2013? (4%)

Quick check

How is a resident citizen taxed on income earned from foreign sources under Section 23(A) of the NIRC?

Why is prize money earned in a professional boxing match in the US not excluded from gross income under Section 32(B)(7)(d)?

How may a resident citizen apply income taxes paid to the US government on foreign prize money when computing Philippine tax liability?

What condition must be satisfied for sports prizes and awards to qualify for statutory tax exclusion under Section 32(B)(7)(d)?

Under Section 34(C), what benefit does a tax credit provide compared to a tax deduction for foreign taxes paid?

Learn more about these topics

1. Worldwide Income Principle
Under Section 23(A) of the National Internal Revenue Code, a resident citizen of the Philippines is taxable on all income derived from sources within and without the Philippines. Unlike non-resident citizens or foreign nationals, resident citizens must declare their global earnings on their Philippine income tax returns. Consequently, prize money won by a resident citizen professional athlete in a foreign country, such as the United States, forms part of gross taxable income subject to regular Philippine income tax rates.

2. Professional Sports Prizes
Under Section 32(B)(7)(d) of the Tax Code, prizes and awards granted to athletes in sports competitions are excluded from gross income only if the competition is sanctioned by their national sports associations and authorized by the Philippine National Sports Commission. However, this statutory exclusion applies strictly to amateur sports competitions. Prizes earned by professional athletes in commercial or professional boxing matches do not qualify for exclusion, rendering the full amount of foreign prize money taxable under Philippine law.

3. Foreign Tax Relief
To alleviate international double taxation when foreign-sourced income is taxed by both the host country and the Philippines, Section 34(C)(1)(b) of the Tax Code permits resident citizens to claim income taxes paid to a foreign government. The taxpayer may elect to claim foreign income taxes paid either as a direct tax credit against Philippine income tax liability, subject to statutory limitations under Section 34, or as a deductible business expense from gross income.

About these questions and answers
The questions reproduced here are the official texts of the Philippine Bar Examinations, published by the Supreme Court. They are reproduced for study purposes.The suggested answers are the author’s own.

They are not official answers, have no connection with the Supreme Court, the Office of the Bar Confidant, or any bar review institution, and are not endorsed by any of them. Official answer keys, where released, should be preferred over anything here.Nothing on this page is legal advice, and reading it creates no lawyer-client relationship. Do not rely on any suggested answer in an actual legal matter. Consult counsel on your own facts.Suggested answers reflect the law and jurisprudence the author considers applicable as of the date shown.

Where a question comes from an earlier examination, the suggested answer applies the law as it now stands, which may differ from the law in force when the question was given, and may therefore differ from what would have been the correct answer at that time. Where the difference is material, the answer notes it.The practice scoring feature measures wording overlap with the suggested answer. It is not a grade, carries no official weight, and says nothing about whether your reasoning is sound.Errors are possible. If you find one, please tell me and I will correct it.Last reviewed: October 2026